Bogus purchase additions and estimation: no substantial question of law arose, so the appeal was not admitted.

In an appeal concerning bogus purchase additions, the Court held that no substantial question of law arose because the Revenue had not challenged the Commissioner (Appeals)' reduction of the addition to 25%, and the Tribunal's further reduction to 12.5% turned only on estimation. On that basis, the dispute was treated as fact-specific rather than involving a legal issue fit for admission, and the appeal was not admitted.

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Issues: Whether the appeal raised any substantial question of law warranting admission, where the addition on account of bogus purchases had been reduced to 25% by the Commissioner (Appeals) and further to 12.5% by the Tribunal.

Analysis: The Court noted that the Revenue had not challenged the Commissioner (Appeals)' reduction to 25%, and the further reduction by the Tribunal only involved an issue of estimation. On that footing, the controversy did not present a question of law, much less a substantial question of law, and the basis ordinarily adopted for admitting similar appeals was held inapplicable.

Conclusion: The appeal did not disclose any substantial question of law and was not admitted.

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