Only the profit element embedded in on-money receipts was held...

Only the profit element embedded in on-money receipts was held taxable, because the Tribunal examined the assessee's disclosed receipts, profit and loss account, gross revenue and project cost, and found that taxing the entire on-money would create an unrealistically high net profit ratio for the real estate business. The Tribunal therefore treated the receipts as containing profit only and, on estimate, enhanced the addition from 20% to 40%. The High Court held this to be a factual appreciation and estimation exercise, not a substantial question of law. Both the Revenue's challenge for full addition and the assessee's challenge to the higher estimate were rejected.