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“profit element”

DisallowancesSection 69CSection 69C5,654 judgments

The decision most relied on for profit element is CIT v. President Industries (258 ITR 654), cited in 471 judgments on BharatTax.

Leading authorities on profit element

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

CIT v. Siemens Aktiongesellschaft
310 ITR 320 · 2009 · High Court
259
citing judgments

Reimbursements of actual expenses without any profit element are not taxable income. Additionally, mere amendments to the Income-tax Act do not override the provisions of Double Taxation Avoidance Agreements (DTAAs).

CIT v. Vijay M. Mistry Construction Ltd.
355 ITR 498 · 2013 · High Court
252
citing judgments

In cases of alleged bogus or hawala purchases where the existence of transactions is not entirely denied, only the profit element embedded in such purchases, and not the entire purchase price, can be added to the assessee's income. The focus is on determining a reasonable profit percentage for such additions.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Vijay Trading Co. v. ITO
388 ITR 377 · 2016 · High Court
119
citing judgments

When purchases are found bogus, only the profit element embedded therein, and not the entire purchase value, can be added to the assessee's income.

NK Proteins Ltd. v. DCIT
292 CTR 354 · 2017 · Supreme Court
115
citing judgments

When purchases are unverifiable or alleged to be bogus, only the profit element embedded in such transactions is taxable, not the entire purchase amount; the onus lies on the assessee to prove the genuineness of the transactions.

Judgments citing profit element

ACIT- CC -3.1, Mumbai vs. I Ahmed & Co.(Cold Storage & Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4782/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

would be met if the addition is restricted to 4% of the purchases from M/s S.A. Enterprises. Such estimation would reasonably account for possible profit element or inflation, without disturbing genuine business activity. 12. Accordingly, the orders of the Ld. CIT(A) is modified and the AO is directed

ACIT-Centrel Circle-3-1, Mumbai vs. I Ahmed & Co.(Cold Storage & Exports) Pvt Ltd., Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4781/MUM/2025[2019-20]Status: DisposedITAT Mumbai18 Feb 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

would be met if the addition is restricted to 4% of the purchases from M/s S.A. Enterprises. Such estimation would reasonably account for possible profit element or inflation, without disturbing genuine business activity. 12. Accordingly, the orders of the Ld. CIT(A) is modified and the AO is directed

ACIT-Central Circle-3.1, Mumbai vs. I Ahmed & Co. (Cold Storage & Exports) Pvt. Ltd, Navi Mumbai

In the result, all six appeals filed by the Revenue are partly allowed in respect of purchases from M/s S

ITA 4711/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19 & Assessment Year: 2019-20 & Assessment Year: 2020-21 & Assessment Year: 2021-22 & Assessment Year: 2022-23 & Assessment Year: 2023-24

Section 133ASection 147Section 148ASection 250Section 37(1)

would be met if the addition is restricted to 4% of the purchases from M/s S.A. Enterprises. Such estimation would reasonably account for possible profit element or inflation, without disturbing genuine business activity. 12. Accordingly, the orders of the Ld. CIT(A) is modified and the AO is directed

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7976/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Feb 2026AY 2016-17

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

same common substratum, namely, purchases treated as unverifiable/non- genuine/bogus on the basis of information from Sales Tax Department and the consequential estimation of profit element thereon, and further, as the parties before us have proceeded on the footing that the issue involved is common and covered by the Tribunal ... purchases are not fully verifiable but sales are accepted and business results are otherwise not rejected, the addition ought to be restricted to the profit element embedded in such purchases, representing possible savings/benefit accruing to the assessee by procuring goods from the grey market at a lower price and regularising

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7975/MUM/2025[2015-16]Status: DisposedITAT Mumbai17 Feb 2026AY 2015-16

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

same common substratum, namely, purchases treated as unverifiable/non- genuine/bogus on the basis of information from Sales Tax Department and the consequential estimation of profit element thereon, and further, as the parties before us have proceeded on the footing that the issue involved is common and covered by the Tribunal ... purchases are not fully verifiable but sales are accepted and business results are otherwise not rejected, the addition ought to be restricted to the profit element embedded in such purchases, representing possible savings/benefit accruing to the assessee by procuring goods from the grey market at a lower price and regularising

Deupty Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Karamtara Engineering Private Limited, Mumbai

In the result, the assessee’s appeal for A

ITA 7974/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Feb 2026AY 2012-13

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

same common substratum, namely, purchases treated as unverifiable/non- genuine/bogus on the basis of information from Sales Tax Department and the consequential estimation of profit element thereon, and further, as the parties before us have proceeded on the footing that the issue involved is common and covered by the Tribunal ... purchases are not fully verifiable but sales are accepted and business results are otherwise not rejected, the addition ought to be restricted to the profit element embedded in such purchases, representing possible savings/benefit accruing to the assessee by procuring goods from the grey market at a lower price and regularising

Karamtara Engineering Limited, Mumbai vs. Central Circle 8(1), Mumbai

In the result, the assessee’s appeal for A

ITA 7973/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Feb 2026AY 2009-10

Bench: Us Have Proceeded On The Footing That The Issue Involved Is Common & Covered By The Tribunal’S Decision In Assessee’S Own Case For Earlier Years, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 131Section 143(3)Section 147Section 254

same common substratum, namely, purchases treated as unverifiable/non- genuine/bogus on the basis of information from Sales Tax Department and the consequential estimation of profit element thereon, and further, as the parties before us have proceeded on the footing that the issue involved is common and covered by the Tribunal ... purchases are not fully verifiable but sales are accepted and business results are otherwise not rejected, the addition ought to be restricted to the profit element embedded in such purchases, representing possible savings/benefit accruing to the assessee by procuring goods from the grey market at a lower price and regularising

Asif Imran Iftekhar Ahmed, Aurangabad vs. Income Tax Officer, Ward 7, Aurangabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2624/PUN/2025[2012-13]Status: DisposedITAT Pune16 Feb 2026AY 2012-13

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2624/Pun/2025 Assessment Year : 2012-13 Asif Imran Iftakhar Ahmed, Vs. Income Tax Officer, 4/14/81, Behind Reliance Medical, Ward-7, Aurangabad Near Toti Ki Masjid, Aurangabad-431001 Maharashtra Pan : Anmpa1200B Appellant Respondent

For Appellant: Shri Prateek JhaFor Respondent: Date of hearing
Section 144Section 147Section 250Section 44ASection 69A

inclined to hold that firstly the transactions appearing in the bank statement are in the nature of business transactions and only the profit element deserves to be added in the hands of assessee. However, since the details of turnover are not placed before this Tribunal, I deem it appropriate

Din Dayal Jalan Textiles Pvt Ltd, Mumbai vs. Asst. CIT 4(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7678/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardin Dayal Jalan Textile Acit-4(1)(1), Pvt. Ltd. Room No. 642, 6Th 904-5, Royal Square, 9Th Vs. Floor, Aayakr Floor, 173, Dr. Vigas Bhavan, Queen Street, Mumbai-400 002 Road, Mumbai – 400 001 Pan/Gir No. Aabcd2310E (Applicant) (Respondent) Assessee By Shri D. C. Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 09.02.2026 Date Of Pronouncement 16.02.2026

Section 132Section 143(3)Section 144BSection 2Section 69A

that books of account were incorrect or incomplete. The assessee further submitted that even assuming without admitting that there were unaccounted purchases, only net profit element could be brought to tax and not the entire amount. 6. The Assessing Officer, however, did not accept the explanation and proceeded to make

Kantilal Ranchhodbhai Nakum, Jamnagar vs. ITO Ward - 1(3), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 551/RJT/2025[2015-16]Status: DisposedITAT Rajkot13 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.551/Rjt/2025 Assessment Year: 2015-16 Kantilal Ranchhodbhai Nakum Income Tax Officer, Ward-1(3), Plot No.762, Gidc, Phase-2, बनाम/ Jamnagar, Aaykar Bhawan, Nr. Dared, Jamnagar-361 004 Vs. Chamber Of Commerce Hall, Jamnagar- Rajkot Highway, Jamnagar-361 001 "ायीलेखासं/.जीआइआरसं./ Pan/Gir No.: Aflpn 8072 P (अपीलाथ"/Appellant) (""थ"/Respondent) : िनधा"रती की ओर से/Assessee By : Shri Ravindra Manek, Ar राज" की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख/Date Of Pronouncement : 13/02/2026 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2015-16, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Cit(A)”] Dated 29.07.2025, Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer U/S 147 R.W.S. 144B Of The Act, On 12.05.2023. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1.The Hon’Ble Cit(A) Erred In Law & On Facts In Confirming Reopening Of Assessment U/S 148 Of The Act.

For Appellant: Shri Ravindra Manek, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 144BSection 147Section 148Section 148ASection 234ASection 250Section 271(1)(c)

well as in fact in confirming addition of entire cash deposit of Rs.3,65,95,312/- without considering the fact that only profit element of the business can be taxed and not the entire deposits. 9. The Hon’ble CIT(A) erred in law and on facts in confirming levy

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Nutech Metal), Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8693/MUM/2025[2011-12]Status: DisposedITAT Mumbai13 Feb 2026AY 2011-12

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

beneficiary of accommodation entries, however, he has given a categorical finding that the purchases were recorded in the books of account, hence, only the profit element embedded therein at 25% in A.Y. 2009-10 and 12.5% in A.Ys. 2010-11 and 2011-12 can be added. Though ... used the word ‘estimate’, while determining the profit element at certain percentage, however, there cannot be any manner of doubt that the determination of (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO suppressed profit element is purely on estimate basis, as the A.O. has not elaborated

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Nutech Metal), Mumbai vs. Income Tax Office Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8692/MUM/2025[2010-11]Status: DisposedITAT Mumbai13 Feb 2026AY 2010-11

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

beneficiary of accommodation entries, however, he has given a categorical finding that the purchases were recorded in the books of account, hence, only the profit element embedded therein at 25% in A.Y. 2009-10 and 12.5% in A.Ys. 2010-11 and 2011-12 can be added. Though ... used the word ‘estimate’, while determining the profit element at certain percentage, however, there cannot be any manner of doubt that the determination of (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO suppressed profit element is purely on estimate basis, as the A.O. has not elaborated

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Netech Metal), Mumbai vs. Income Tax Office Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8691/MUM/2025[2009-10]Status: DisposedITAT Mumbai13 Feb 2026AY 2009-10

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

beneficiary of accommodation entries, however, he has given a categorical finding that the purchases were recorded in the books of account, hence, only the profit element embedded therein at 25% in A.Y. 2009-10 and 12.5% in A.Ys. 2010-11 and 2011-12 can be added. Though ... used the word ‘estimate’, while determining the profit element at certain percentage, however, there cannot be any manner of doubt that the determination of (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO suppressed profit element is purely on estimate basis, as the A.O. has not elaborated

Talshibhai Kanjibhai Narola, Damnagar vs. The ITO WD 3(1)(4), RKT, Amreli-Rajkot

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 980/RJT/2025[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Ms. Devina Patel, Ld. A.R
Section 115BSection 147Section 148Section 250(6)Section 69A

upholding the action of assessing officer in making gross addition of Rs. 19,08,451/- and failed to appreciate that at best only profit element embedded in alleged transaction could be treated as income and not entire transaction. 6. The appellant craves leave to add, amend, alter and withdraw

M/S Bhagyesh A. Patel, Mumbai vs. ACIT 19 (1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5865/MUM/2025[2012-13]Status: DisposedITAT Mumbai12 Feb 2026AY 2012-13

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ajay R. Singh, Adv, & Akshay Pawar, AdvFor Respondent: Shri Leyaqat Ali Aafaqui (SR DR)
Section 143(3)Section 148Section 250Section 69C

Bombay High Court in Hitesh A. Shah v ITO has supported this view. 5. Full Addition Under Section 69C Justified; No Estimation of Profit Element: Since no goods were actually purchased (bogus entries), the entire amount represents unexplained expenditure, warranting 100% addition. Estimation of profit (e.g., GP rate) applies only ... transactions are wholly sham. Treating them as accommodation entries aligns with the business realities uncovered. The plea for restricting the disallowance to the "profit element" is untenable. The investigation conclusively proved that the purchases themselves were non-genuine, and only bills were obtained without any actual movement of goods. When

Deepak Kumar Prop. M/S Urvi Enterprises Mandigobindgarh, Mandi Gobindgarh vs. The Assessment Unit NFAC Delhi Jao the Income Tax Officer Ward-2 Mandi Gobindgarh, Mandi Gobindgarh

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 103/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh11 Feb 2026AY 2022-2023
For Appellant: Shri Rohit Garg, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR
Section 133(6)Section 142(1)Section 144Section 144BSection 250

rejected. Considering the facts of the case and following the settled judicial principle that in cases of non-genuine or unverifiable purchases the profit element embedded therein is to be brought to tax, an amount equal to 12.5% of the total purchases amounting to Rs.41,76,55,696/-, i.e., Rs.5 ... note that the Assessing Officer, in the facts and circumstances of the case, has not disallowed the entire purchases but has estimated the profit element at 12.5% on the alleged unverifiable purchases, which is a reasonable and judicially recognised approach consistently adopted in similar cases. We further observe that

R J Corporation, Mumbai vs. Income Tax Officer, 42(1)(4), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 7715/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Feb 2026AY 2011-12

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

account under section 145(3) of the Act. However, since the sales declared by the assessee were not doubted, the Assessing Officer estimated the profit element embedded in such purchases at 12.5 percent and made additions accordingly. In the respective assessment orders passed under section 143(3) read with section ... information received from the Sales Tax Department alleging bogus purchases. The Assessing Officer rejected the books under section 145(3) and estimated the profit element embedded in the purchases at 12.5 percent and further made an addition towards alleged commission. Penalty under section 271(1)(c) was thereafter levied

R J Corporation, Mumbai vs. Income Tax Officer, 42(1)(4), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 7714/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Feb 2026AY 2010-11

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

account under section 145(3) of the Act. However, since the sales declared by the assessee were not doubted, the Assessing Officer estimated the profit element embedded in such purchases at 12.5 percent and made additions accordingly. In the respective assessment orders passed under section 143(3) read with section ... information received from the Sales Tax Department alleging bogus purchases. The Assessing Officer rejected the books under section 145(3) and estimated the profit element embedded in the purchases at 12.5 percent and further made an addition towards alleged commission. Penalty under section 271(1)(c) was thereafter levied

Adds Aquaculture Private Limited, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 577/NAG/2025[2017-18]Status: DisposedITAT Nagpur10 Feb 2026AY 2017-18

Bench: Dr. Manish Borad

For Appellant: Shri Abhay Agrawal, AdvocateFor Respondent: Shri Surjit Kumar Saha, Sr.DR
Section 139Section 144Section 148Section 250

filed by the assessee to explain that total turnover including the alleged cash deposits is the total turnover of the year and that only profit element on such business turnover is liable to be taxed. Needless to mention that Ld. JAO shall afford a reasonable opportunity of being heard

Kamlesh Kumar Aggarwal, Delhi vs. ITO Ward 49(4), Delhi

Appeal is partly allowed

ITA 7182/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7182/Del/2025 : Asstt. Year: 2017-18 Kamlesh Kumar Aggarwal, Vs Income Tax Officer, D-59, Mayapuri, Phase-Ii, Ward-49(4), New Delhi-110064 New Delhi-110002 (Appellant) (Respondent) Pan No. Aafpa8150N Assessee By: Sh. Atul Puri, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1079468935(1) Dated 11.08.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Atul Puri, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 115BSection 143(3)Section 68

deemed appropriate in this larger interest of justice that a lump sum addition of Rs.2,50,000/- representing the assessee’s profit element in the said cash deposits would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow