The Tribunal held that although purchases from three parties remained unverifiable, the books of account had not been rejected under section 145(3) and the turnover was accepted by the Revenue. Therefore, the settled principle that only the profit element embedded in such purchases is liable to tax was applicable. Considering the nature of the assessee’s business as a wholesaler of building material and civil contractor, the Tribunal held that estimation of gross profit at 5% on the unverifiable purchases, after reducing the GP already declared, was reasonable. Invocation of section 69C was held to be unwarranted. (AY.2021-22)