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2012 (9) TMI 46 - ITAT, BANGALORERevision u/s 263 / rectification u/s 154 - unascertained liability as shown in P/L A/C in view of the provisions of Explanation(c) to Sec 115JB - Held that:- As the order u/s 263 was passed the law was that provision for bad and doubtful debts cannot be added to the profit as per profit and loss account while computing book profit u/s 115JB . The retrospective amendment to the provisions of Sec.115JB cannot give power to the ACIT to rectify his order u/s 263 , which as on the date when the order u/s 263 was passed was in accordance with law - What could not have been done in the order u/s 263 as on the date when it was passed cannot be done by exercise of powers of rectification u/s 154, thus the impugned order of CIT rectifying his order u/s 263 by exercising powers u/s 154 cannot be sustained - in favour of assessee.
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