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The HC upheld the Tribunal's reduction of the disallowance on cash purchases from 15% to 5%, noting the original disallowance lacked factual basis and was arbitrary. The court found no justification for any disallowance under relevant provisions, as the cash transactions were within permissible limits and no statutory violations were established. Although the assessee accepted the 5% disallowance, the HC expressed that no disallowance was warranted but sustained the Tribunal's order due to the assessee's acceptance and absence of compelling legal arguments from the Revenue. Both substantial questions of law were decided in favor of the assessee, resulting in the dismissal of the Revenue's appeal and affirming the reduced disallowance.
The HC upheld the Tribunal's reduction of the disallowance on cash purchases from 15% to 5%, noting the original disallowance lacked factual basis and was arbitrary. The court found no justification for any disallowance under relevant provisions, as the cash transactions were within permissible limits and no statutory violations were established. Although the assessee accepted the 5% disallowance, the HC expressed that no disallowance was warranted but sustained the Tribunal's order due to the assessee's acceptance and absence of compelling legal arguments from the Revenue. Both substantial questions of law were decided in favor of the assessee, resulting in the dismissal of the Revenue's appeal and affirming the reduced disallowance.
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