The assessee, engaged in trading and export-import of garments and textiles, was found to have made purchases of ₹2.19 crores from three concerns alleged to be hawala dealers. The AO, in reassessment proceedings, treated 18.5% of such purchases as bogus and added ₹40.57 lakhs. On appeal, the CIT(A) restricted the disallowance to 12.5% of purchases. Before the Tribunal, the assessee contended that the addition should be restricted to 5%, while the Revenue sought restoration of 100% addition relying on PCIT v. Kanak Impex (India) Ltd. (2025) 474 ITR 175  / 172 taxmann.com 283 (Bom.)(HC)  The Tribunal held that the facts of Kanak Impex were distinguishable since in that case the assessee had not appeared in reassessment proceedings, whereas in the present case the assessee furnished purchase invoices, bank statements, and evidence of sales. Following consistent Tribunal precedents, the ITAT upheld the CIT(A)’s estimation at 12.5% and rejected both the assessee’s plea for further reduction and the Revenue’s plea for enhancement. Appeals of both parties were dismissed. Referred , ITO v. Pradeep Kumar Agarwal (ITA No. 1544/JPR/2024) dated 04.04.2025 (Jaipur)( Trib),  ACIT v. Dhiraj Parbat Gothi (ITA No. 580/Mum/2025) dated 30.05.2025 (Mum)( Trib) , ITO v. Khimchand Okchand Bhansali (2025) 174 taxmann.com 148 (Mum)( Trib) , Quality Heightcon Pvt. Ltd. v . DCIT (ITA No. 1489/Mum/2025) dated 07.05.2025 (Mum)( Trib) , ITO v.  Mangalam Drugs & Organics Ltd. (ITA No. 5279/Mum/2015) dated 08.05.2025 (Mum)( Trib) , Rajesh Shivji Shah v. ITO (ITA No. 525/Mum/2025) dated 29.04.2025 (Mum)( Trib)  . (ITA Nos. 2561/Mum/2025 & 2939/Mum/2024, dt. 28.07.2025 )( AY. 2011 -12 )