Assessee was engaged in business of dealing in ferrous and non-ferrous metals . It made purchases through banking channels and filed relevant purchase invoices, copy of bank statements evidencing payment made through proper banking channels, chart showing details of purchases made from parties and corresponding sales   Assessing Officer held  that sales tax department had given information with regard to bogus accommodation entries on account of bogus purchases/bills hence he estimated profit element at rate of 12.5 per cent of total purchases made by assessee which were claimed to be bogus and made addition under section 69C .  Commissioner (Appeals) restricted addition from 12.5 per cent to 4 per cent of bogus purchases  . On appeal the Tribunal held that   since assessee had proved that transactions had been carried out through banking channels and Assessing Officer had not doubted same, addition made by Assessing Officer at rate of 12.5 per cent could not be restored ,  however, considering peculiar facts and circumstances, addition was to be restricted at rate of 5 per cent instead of 4 per cent as restricted by Commissioner (Appeals) . Decision in  PCIT v. Kanak Impex (India) Ltd 2025] 474 ITR 175 / 172 taxmann.com 283 (Bom)( HC)  distinguished .    (AY. 2009 -10 , 2011 -12 )