Disallowance of expenses on estimation, not allowed

Brief of the Case ITAT Ahmedabad held in the case of ITO vs. M/s Buildcon Engineers that the AO had made disallowance of labour payments on the basis of estimation to the extent of 20% of the expenditure. The AO has not given any basis on which he has based his finding to disallow at 20% of the expenditure on estimate basis. In our considered view, if the payment is bogus, it would be 100%. The CIT (A) has given his finding on the fact that the PAN furnished during the appellate proceedings was found to be correct, which was the sole reason for addition. Under these facts, we do not see any re...