Yes, it can be 3-5L, but you created a money trail of 40 Lakhs with all transactions. When there is an enquiry from IT they ask proofs for all of it. Do you want to go through the hassle of it. In the end you many come out clean but it will cost you more and spend a lot of time around it.
PS: My friend made a small mistake while filing ITR, because of which IT took 2L from his refund. Later he rectified the filing. Now, it has been more than 6 months he paid CA 10K+ to get that 2L back. Get the lesson from here.