Assessing Officer disallowed  entire purchases, considering it unexplained expenditure under section 69C of the Act.   On appeal, Commissioner (Appeals) held  that since Assessing Officer did not doubt genuineness of payments made through banking channels and accepted total sales, entire purchases couldn’t be disallowed.  Instead, only profit element was considered, restricting unexplained expenditure to 8 per cent of total purchases.  Tribunal accepted factual finding recorded by Commissioner (Appeals). On appeal dismissing the appeal of the Revenue the Court held that  since both Commissioner (Appeals) and Tribunal concluded, based on facts, that 8 per cent was a reasonable figure, there was no justification for interfering with orders of lower authorities. (AY. 2011-12)