The original assessment was made by the Assessing Officer rejecting the books of account of the assessee and estimating the income of the assessee at 8 per cent. of the gross contract receipts. Once the books of account of the assessee were rejected, the books could not be relied on for making addition under S. 69 in reassessment proceedings. (AY. 2009-2010 )
Hemant Kumar Pradhan v. ITO (2018) 62 ITR 57 (Cuttack)(Trib.)
S.69: Unexplained investments – Books rejected in original proceedings and income estimated at 8 percent. of the gross contact receipts- Addition cannot be made u/s 69 in reassessment proceedings. [S.147]