TDR Sale Bank Credits: ITAT Rejects Books, Applies 12% Profit Rate

Sai Vishwa Promoters Builders And Developers Vs ITO (ITAT Pune) Assessee, a partnership firm engaged in construction & slum rehabilitation projects, received ₹85,00,000 from sale of Transferable Development Rights (TDR) on 07.04.2008. It did not file return of income. Based on bank information showing total credits of ₹1,93,64,405, AO reopened the case u/s 148 & completed assessment ex parte u/s 144, treating ₹85 lakh as business income from TDR & the balance ₹1,08,64,405 as unexplained income u/s 68. Before CIT(A), Assessee explained that it had incurred business expenditu...