2022 (9) TMI 1466

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....d 20.12.2017 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the ld. AO, Additional CIT, Special Range-6, New Delhi (hereinafter referred as the Ld. AO). 2. The brief facts of the case as put up by assessee are that it is a Public Sector Undertaking formed with the sole object of reviving sick textile mills mainly to safeguard the interest of labourers employed by them and also having huge b/d unabsorbed losses of Rs 1,545.08 Crores during the current A.Y. 2015-16. Further it is also not liable to pay taxes as per BIFR mandate. It filed its E- Return as on 29th Sep 2015 declaring total losses of Rs 229.89 Crores. The case was selected for scrutiny & statutory notice u/s 143(2) was duly served on....

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....sions for no further Prior Period Expenses disallowance of Rs 2,23,09,000/-as follows:- a. The Assessee has himself disallowed Rs 49,31,02,928/- as per law. b. The Assessee is disallowing Net Prior Period Expenses (Prior Period Expenses- Prior Period Income) since inception 01/04/1968 (Last 45 years). c. The changing from Net to Gross Prior Period Expenses shall have no effect on tax liability over a period as these are self-adjustable. d. These are CURRENT YEAR expenses only but reported as prior period in compliance of Accounting Standards-5 of ICAI & Companies Act 2013 only. This fact was duly proved also as per stated judicial findings. e. The similar disallowances made in the earlier assessment years were duly struck down als....