Profit Element Disallowed in Hawala Transactions; 12.5% Rate Deemed Excessive, Restricted to 6% for Bogus Purchases.

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....Estimation of income for bogus purchases - It is settled law that in case of disputed purchases shown from such hawala dealers only the profit element embedded in such transaction, to avoid the possibility of revenue leakage, is to be disallowed, and not the substantial part of the transaction. No doubt the assessee has shown extremely low G.P yet the disallowance at rate of 12.5% is on higher side. - restricted the addition of similar bogus/ impugned purchase to the extent of 6% - AT....