AO estimated profit @10% of gross receipts which is in violation of principles of natural justice without considering that assessee has maintained books of accounts which have been audited. Further, provisions of Section 44BBB(1) not applicable to the assessee and assessee setup PE for expansion of oil refinery project and not related to turnkey project approved by Central Government. Even otherwise, if assumed that 44BBB(1) applicable, then 44BBB(2) overrides 44BBB(1). Where assessee had maintained books of accounts as per 44AA and audited as per 44AB, then provisions of S. 44BBB(1) not applicable. AO could not have estimated net profit @10%. Addition made by AO  is deleted. (AY.  2019-20)