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

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