Devi Construction Company v. DCIT (2020) 185 ITD 858/193 DTR 225/207 TTJ 130 (Pune)(Trib.)

S. 69C : Unexplained expenditure-Bogus purchases-Ad-hoc addition-Only difference between gross profit rate on genuine purchases and gross profit rate on alleged hawala can be added-Once reassessment is held to be valid-Free to assess any other income. [S.147, 148]

Tribunal held that for alleged bogus purchases, ad hoc addition cannot be made rather same has to be made to extent of difference between gross profit rate on genuine purchases and gross profit rate on hawala purchases. Tribunal held that, once reassessment proceedings are held to be validly initiated, Assessing Officer is free to assess any other income which comes to his notice in course of proceedings under section 147.  (AY. 2011-12)