completeness, we may also address the issue
regarding applicability of section 44BBB(1) of the Act. On a
careful reading of the said provision ... Central Government or a competent authority in terms of section
44BBB(1) of the Act. Even, assuming that section 44BBB
applies, sub-section
DDIT (2008) 113 TIJ 446 and seeking guidance from section
44BBB of the Income-tax Act, 1961, the Assessing Officer, in the
reasons recorded
applying the provisions of deemed profitability as per
Sections 44BB and 44BBB of the Act, the assessing officer had
attributed 35% of such profits from ... suffer from any infirmity, inasmuch as,
the AO relied upon Section 44BBB of the Act and estimated 10% of
receipts as deemed profit and taxed
India. Applying
the provisions of Section 44BB and 44BBB, deemed profitability of
10% of the gross receipts from the supply of spares and offshore
repairs
Whether the Ld. ITAT erred in law in holding that section
44BBB was not applicable to the case of the Assessee since the
contract
Whether the Ld. ITAT erred in law in holding that section
44BBB was not applicable to the case of the Assessee since the
contract
Whether the learned ITAT erred in law in holding that
the section 44BBB was not applicable to the case of the
Assessee?
C. Whether learned