Assessee company derived income from business of manufacturing of jewellery and trading of gemstones. On the basis of information from investigation Wing a search action was conducted on the assessee and on the basis of material seized income was estimated at 15% of bogus purchases. On appeal the Tribunal reduced the GP from 15 % to 12%.   On appeal by the assessee, dismissing the appeal of the assessee the Court held that finding recorded by Tribunal was a finding of fact based on material on record, no substantial question of law arose.   (AY. 2007-08)