Court Rules Only Profit Element Disallowed on Bogus Purchases; 12.5% Disallowance Rate Deemed Fair by Commissioner (Appeals.

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....Estimation of income - Bogus purchases - The doubt, if any, is only with regard to the source of purchases. In such circumstances, the entire purchases cannot disallowed. As rightly observed by Commissioner (Appeals), only the profit element embedded in such purchases can be considered for disallowance. - disallowance @ 12.5% of the alleged non–genuine purchases is fair and reasonable - AT....