S. 143(3): Assessment-Jurisdiction-Income include loss-Corporate assessee-Jurisdiction was with ACIT/Dy. CIT-The assessee had disclosed loss of Rs. 3,29,55,888-Notice is valid-Rejection of books of account is justified-Estimate of 10 percent of net profit is reasonable. [S. 2(24), 120, 143(2), 145(2)]

S. 143(2) : Assessment-Notice-Shifting of residence from Delhi to Gurgaon-Change is reflected in the return filed-Notice issued by the Assessing Officer from Delhi is without jurisdiction-Quashed-Additional ground-Jurisdictional issue-Admitted [S. 254(1)]

S. 143(1) : Assessment-Intimation-Failure to file Form No 10B-Adjustment is justified-Disallowance of expenditure-Revenue is directed to intimate the exact reason for disallowing the claim of the assessee while processing the return-The assessee may file an application under S. 154 to rectify the mistake in the intimation, as deemed proper-Assessee is also free to avail the remedy under s. 119 if it so desires. [S. 10(23C), 11, 119, 154, 250(5)]

S. 143(1) : Assessment-Intimation-Prima facie adjustment-under late payment of employees’ contribution towards PF and ESI-Adjustment is valid-Not allowable as deduction. [S.36(1(va), 37(1), 143(1)(a)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-comparables-There is no error in the reasons given by the TPO/DRP to include L&T in the final set of comparables-PLR-Interest on outstanding receivable-TPO is directed to adopt appropriate rate of interest by considering the currency in which the outstanding receivable by the assessee and its AE. [S.92B]

S. 80G : Donation-Time-limit for filing application for final approval-Form No. 10AB was filed on 23rd Sept., 2023 was well within time i.e., within six months prior to the expiry of the period of provisional approval-Order of the CIT(E) is set aside with direction to pass a fresh order on merits as provided in law. [S.12A(1)(ac)(vi), 80G(5)(iii)]

S. 80G : Donation-Time-limit for filing application for final approval-Existing Trust or institution-Applied for permanent registration under S. 80G before the expiry of provisional approval-The application of the assessee was not time-barred-The order under s. 80G is set aside to CIT(E) for de novo adjudication-Speech of the Finance Minster is relevant. [S.12AB, 80G(5)]

S. 69A : Unexplained money-Cash deposits-Demonetization-Petrol pump-Not violated any provision of law or any Government guidelines-Addition is deleted.

S. 69A : Unexplained money-Cash deposit-Demonetization-Sufficient stock-Sales-Sales shown in VAT return-Addition is deleted.

S. 69A : Unexplained money-Demonetisation-Bank notes-Complete record is maintained-Receipts from the customers cannot be assssed as unexplained.