Estimation of income from alleged bogus purchases: appellate challenge dismissed; 3% arbitrary estimate finally rejected.

Primary onus to prove bona fides of purchases governs assessment of alleged bogus purchases; an arbitrary fixed-percentage approach cannot substitute evidentiary assessment. The tribunal's uniform 3% estimation of bogus purchases was found inconsistent with settled precedent and therefore unsustainable, leading to reversal of that specific quantification. The appellate process was exhausted with the higher forum refusing to interfere with the High Court's corrective reasoning, resulting in dismissal of the special leave challenge.

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Having heard counsel and having reviewed the materials on record, the Court found "no good reason to interfere with the impugned orders passed by the High Court." On that basis, the Court dismissed the Special Leave Petitions: "The Special Leave Petitions are, accordingly, dismissed." The order expressly records that the Court considered submissions of the petitioner and the record but declined to disturb the High Court's determinations. All pending applications connected to the petitions were also disposed of. The disposition is summary in nature and rests on the absence of grounds warranting interference with the High Court's orders rather than on a detailed interlocutory analysis of the substantive merits.

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