Unrecorded cash paid as on-money for commercial property, where...

Unrecorded cash paid as on-money for commercial property, where established on the evidentiary standard applicable to income-tax proceedings, is taxable only to the extent of the profit element embedded in the payment, since income tax applies to income rather than gross receipts. The assessable addition was confined to 10% of the unrecorded payment and made taxable at normal income-tax rates rather than under section 115BBE.