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2021 (7) TMI 637 - AT - Income TaxRectification u/s 154 - provision for outstanding derivatives contract written back and the provision for doubtful debts was not added back - non disclosure of MAT computation - HELD THAT:- Admittedly, the provisions for outstanding derivatives contract written back was reduced from the book profits for asst. year 2008- 09 cannot be allowed for the reason that the appellant was assessed to tax under the regular provisions of the act for assessment year 2008-09. It is also a fact that for assessment year 2008-09, AO made additions for the said provision under the normal provisions of the Act - MAT provisions were not applicable to assessee in the asst. year 2008-09. However the argument of assessee to treat it as a deemed disallowance under MAT for asst. year 2008-09 can’t be accepted. No infirmity in the view taken by the Ld.CIT(A) that any reversal of such provision in a subsequent assessment year was to be considered as usual treatment in tax, and the same does not fall within the ambit of “overlooking of statutory provisions”. This under no circumstances could be deemed as failure to compliance of statutory provisions by the Ld.AO which could be rectified u/s 154. - Decided against assessee.
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