S. 143(3) : Assessment-Income from undisclosed sources-estimate of income-Suppression of both purchases and sales-Gross profit alone to be assessed and not entire suppressed sales.-Prior period expenses-Disallowance is justified-Sundry creditors-Matter remanded. [S. 37(1), 69]

S. 143(2) : Assessment-Notice was issued by ITO Belgaum-Actual Assessing Officer id from Bellary-Notice was issue without jurisdiction-Order was quashed. [S. 10(10D), 127, 143(3)]

S. 143(1)(a) : Assessment-Intimation-Prima facie adjustments-Capital gains-Exemption denied-No intimation before making adjustments-Adjustments is not sustainable. [S. 11(1A), 11(2)]

S. 124 : Jurisdiction of Assessing Officer-Objection to jurisdiction cannot be challenged after completion of Assessment-Assessee submitting to jurisdiction of Assessing Officer by filing return-issue not raised in assessment proceedings-Assessment valid.[S. 124(3)]

S. 115JB : Book profit-Provision for expenses-Ascertained liability-Cannot be added back. [S. 37(1)]

S. 115JB : Book profit-Relief for a period of 8 years-Not entitle to relief from claiming further relief after its net worth turned positive during said scheme period. [S. 115JB(2), Expln. 1 (vii), Sick Industrial Companies (Special Provisions, Act, 1985, S. 17(1), 18(12)]

S. 115JB : Book profit-Fertiliser subsidy received treated as capital receipt and not chargeable to tax, it had to be excluded from computing book profit. [S. 4]

S. 115A : Foreign companies-Tax-Dividends-Royalty-Technical services fees-Rate of tax-Matter remanded-DTAA-India-USA. [S. 115A(b), Art. 12]

S. 94 : Transaction in securities-Unless interest arising and accruing from security is deemed to be income of owner who transferred the securities loss cannot be disallowed. [S. 45, 94(4)]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally different from assessee to be excluded from list of comparables-Transactional net margin method-Foreign exchange fluctuation gains on re-statement of outstanding debtors as on balance-sheet date-Part of operating revenue-Assessee within ± 5 Per Cent. tolerance range-No transfer pricing adjustment called for. [S. 92C(2)]