The responded is in business in trading and manufacturing of silver, gold, diamonds stones and Jewellery. The AO on the basis of report of investigation wing Mumbai  where in two purchases were made from Amit Diamonds which belongs to Bhanvarlal Jain group being a hawala concern, made addition of entire purchases. CIT(A) deleted the addition and confirmed 3% of amount of purchases. Tribunal affirmed the order of the CIT(A). On appeal by the revenue, dismissing the appeal of the revenue the Court held that the CIT(A) had found that the assessee had shown purchases as well as sales. If the sales were accepted, the Assessing Officer could not have rejected the purchases. Once the purchases were accepted, the difference between the inflated and actual price of purchases would be required to be disallowed and what would be the extent of difference would be a matter of estimate. The Commissioner (Appeals) had estimated this difference at 3 per cent. of the bogus purchases and the Tribunal had accepted it. Whether an estimate should be at a particular sum or at a different sum can never be an issue of law. (Followed Sanjay Oilcake Industries v CIT ( 2009) 316 ITR 274 (Guj.)(HC)  Referred  N.K. Industries Ltd. v Dy CIT ( 2017) 292 CTR 354/ 8 ITR-OL 336  (Guj.)(HC), Vijay Proteins Ltd v. CIT (2015) 58 taxmann.com 44 (Guj.) (HC)   (AY. 2011-12)