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Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
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TaxTMI 
TaxTMI 
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