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The Deputy Commissioner of Income Tax Versus M/s. Microlabs Ltd.

2015 (3) TMI 982 - ITAT BANGALORE

Rectification order U/s 154 - Commissioner of Income Tax passed a rectification order U/s 154 allowing R & D expenditure U/s 35(2AB) on the net expenditure after reducing sales realized - Whether CIT(A) erred in not following the substance of DSIR guidelines which indicates that the sales realization arising out of assets sold should be reduced while claiming the deduction but the he erred in reducing the sale of products out of R & D expenditure? - Held that:- DSIR guidelines no. vii has specif .....

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that the product development charges received by the assessee will not be covered under clause 5(vii) of the DSIR guidelines. As we have already seen, these receipts are credited to profit & loss account are part of normal sales. They are, therefore, not to be reduced from the expenditure incurred by the assessee on carrying out scientific research on which deduction u/s. 35(2AB) has to be allowed. We are, therefore, of the view that there is no merit in ground raised by the revenue and that the .....

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“expenditure incurred by the Assessee in relation to”. Both the expressions mean that whatever expenditure are incurred to earn income which does not form part of the total income under the Act, both direct and indirect expenditure, have to be disallowed. There is no basis for the argument u/s. 115JB of the Act, it is only direct expenses that are contemplated as capable of being added to the profits as per P&L account under clause (f) to Expln.1 below Sec.115JB(2) of the Act. Also the quantum o .....

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case also, however, with the modification that the quantum of deduction u/s. 14A of the Act which is determined while computing the total income of assessee under normal provisions of the Act and which is ultimately sustained by the Tribunal will be substituted with the sum disallowed by the AO. - Decided in favour of revenue.

Disallowance u/s. 14A read with rule 8D - appellant has not produced the evidentiary support in relation to dispersal of loan and utilization of loan - Held th .....

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e out of interest free funds and no disallowance u/s. 14A towards any interest expenditure can be made. Also when investments are made out of common pool of funds and non-interest bearing funds were more than the investments in tax free securities, no disallowance of interest expenditure u/s. 14A can be made. Thus disallowance of interest expenses in the present case of ₹ 49,42,473 made under Rule 8D(2)(ii) of the I.T. Rules should be deleted. - Decided in favour of assessee

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j & Boyce Mfg. Co., (2010 (8) TMI 77 - BOMBAY HIGH COURT), it was held that Rule 8D can be resorted to by the AO only when he rejects the claim made by the assessee regarding expenditure incurred in earning income which does not form part of total income. In the present case, the AO has not done so. We therefore deem it fit and proper to restore this issue of disallowance under Rule 8D(2)(iii) to the AO for fresh consideration - Decided in favour of assessee for statistical purposes.

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to verify the claim of assessee to the extent that the provision for wealth-tax is based on the actual wealth-tax returns filed by the assessee (and if so), then the same cannot be considered as unascertained liability - Decided in favour of assessee for statistical purposes. - ITA No.1412/Bang/2013, ITA No.1429/Bang/2013 & 764/Bang/2014 - Dated:- 5-3-2015 - Shri N.V. VASUDEVAN And Shri Jason P. Boaz JJ For the Appellant : Shri C.H. Sundar Rao, CIT-I(DR) For the Respondent : Shri S. Parthasarthi .....

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Nos. 1412/12 & 764/13 2. First we shall take up for consideration the appeals by the revenue in ITA No.1412/B/13 and that of the assessee in ITA No.764/B/14 against the order u/s. 154 of the Act. 3. Ground No.2 raised by the revenue in its appeal and the grounds raised by the assessee in its appeal arise out of identical facts and circumstances and are therefore taken up for consideration together. The grounds of appeal are as follows:- Revenue s ground 2. The Ld CIT(A) erred in allowing th .....

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he Appellant filed the Appeal before the Commissioner of Income Tax and he is allowed deduction U/s 35(2AB) on the gross expenditure. However the Learned Commissioner of Income Tax has passed a rectification order U/s 154 allowing R & D expenditure U/s 35(2AB) on the net expenditure after reducing sales realized. 2. The Learned Commissioner of Income Tax has erred in not following the substance of DSIR guidelines which indicates that the sales realization arising out of assets sold should be .....

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he case of T.S.Balaram ITO Bombay Vs Volkart Brothers & Others 82 ITR 50. 4. The facts material for adjudication of the aforesaid grounds of appeal, are as follows. The assessee is a company engaged in the business of manufacture of pharmaceuticals. It is not in dispute that the assessee was entitled to claim weighted deduction u/s. 35(2AB) of the Act. The provisions of Sec.35(2AB) of the Act in so far as it relates to the dispute in the present appeal are as follows: Sec.35 (2AB)(1) Where a .....

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diture so incurred. Explanation : For the purposes of this clause, "expenditure on scientific research", in relation to drugs and pharmaceuticals, shall include expenditure incurred on clinical drug trial, obtaining approval from any regulatory authority under any Central State or Provincial Act and filing an application for a patent under the Patents Act, 1970 (39 of 1970). (2) No deduction shall be allowed in respect of the expenditure mentioned in clause (1) under any other provisio .....

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nditure referred to in clause (1) which is incurred after the 31st day of March, 2017. (6) No deduction shall be allowed to a company approved under sub-clause (C) of clause (iia) of sub-section (1) in respect of the expenditure referred to in clause (1) which is incurred after the 31st day of March, 2008. 5. The assessee had quantified the deduction u/s. 35(2AB) at a sum of ₹ 12,57,00,920. It had received a sum of ₹ 57,47,808 as product development charges. The Assessing Officer was .....

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l Expenditure 7,80,52,805 Deduction u/s35(2AB) at 150% of the R & D expenditure (Deduction to be a1lowed) 11,70,79,207 Less Deduction u/s 35(2AB) claimed in the return of income 12,57,00,920 Excess deduction claimed to be disallowed 86,21,713 6. Aggrieved by the order of AO, assessee filed an appeal before the CIT(Appeals). The CIT(A) held that deduction claimed by the assessee u/s. 35(2AB) has to be allowed as the provisions of Sec.35(2AB) of the Act talk only about expenditure and does not .....

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imes of the expenditure Incurred (emphasis added). A plain reading of this section shows that the entire expenditure ( any expenditure ) incurred for In-house R & D facility is expected to be allowed as a deduction ( so incurred ) and the interpretation of the deduction as being for net expenditure is nowhere evident from the provision. Accordingly, the appellant s claim of weighted deduction on the gross revenue expenditure is held to be in order. This ground, therefore, succeeds. 7. Aggrie .....

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es realization arising out of assets sold should be offset against R&D expenditure. It is after taking note of this guideline that the CIT(A) initiated proceedings u/s. 154 of the Act. 8. In reply to the show cause notice issued u/s.154 of the Act proposing to rectify her original order, the assessee submitted before the CIT(A) that the guidelines provides for set-off of realization of sale of assets used for R & D activities. This is obvious since the cost of assets is allowed as deduct .....

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;D for considering the deduction u/s. 35(2AB) of the Act. There being no infirmity in the appellate order or there being no mistake apparent from the appellate order, the proposed action is without jurisdiction and unwarranted. 9. The CIT(A), however, did not agree with the submissions of the assessee and held that substance of the DSIR guidelines clearly indicate the reduction of receipts related to the in-house R & D Centre from the gross expenditure outflow on R & D. He was of the vie .....

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led appeal being ITA No.764/B/14. 11. The issue that needs to be decided now is as to, what is the nature of product development charges of ₹ 57,47,808 received by the assessee? The details from whom the aforesaid sum was received which is at page 37 of the PB is given as ANNEXURE-I to this order. 12. We have heard the submissions of the ld. DR and the ld. counsel for the assessee and also perused the documents filed in paperbook. As we have already seen, the assessee carries on scientific .....

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g approval of the scientific research carried out by the assessee as eligible for deduction u/s. 35(2AB). A copy of the guidelines of DSIR is at pages 27 to 33 of assessee s paperbook. Guideline 5(vii) is relevant for the present case and it reads as follows:- (vii) Assets acquired and products, if any emanating out of R&D work done in approved facility, shall not be disposed off without approval of the Secretary, DSIR. Sales realisation arising out of the assets sold shall be offset against .....

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ing out the R&D work, if the assessee acquires any assets or products that should not be disposed of without the approval of Secretary, DSIR. If such assets are sold, the sales realization arising therefrom are to be setoff against the R&D expenditure of the R&D centre which is claimed as deduction u/s. 35(2AB). It is evident from the above guideline that it is only sales realization arising out of the assets sold that should be offset against R&D expenditure. In respect of sale .....

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oducts will not go to reduce the expenditure on R&D, whereas the assets acquired in the process of carrying out the R&D if they are sold, such sales realization would go to reduce the expenditure on scientific research and that is why sales realization arising out of assets sold is required to be offset against R&D expenditure. The above explanation will be sufficient to hold that the order passed by the CIT(A) u/s.154 of the Act is unsustainable. Nevertheless, we will also examine a .....

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carrying out scientific research. This would also include the requirement of health authorities for grant of license to approve the products for human use. The assessee gives the Dossiers so prepared to entities outside India, who are interested in getting the marketing authorization for the product in a particular territory. They pay to the assessee the Dossier charges and apply for license to market the products for human use in their respective territories. On getting the license, they get ma .....

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get rights to market the assessee s products in their territory and the actual manufacture in course of time will be done by M/s. Micro Labs Limited i.e., the Assessee. 15. All intellectual property rights, title and interest of any kind whatsoever in and/or to the Dossier and the Products shall be the exclusive property of MICRO LABS (the Assessee). MICRO LABS i.e., the Assessee may sell the Dossier to any third party, including its clients without the consent of foreign entity buying the dossi .....

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mp; accounts of approved R & D sanction to DSIR. The R & D accounts have been separately maintained and separate P & L Account prepared and the dossier sales have been credited to P & L Account of R & D because these sales are part of normal sales. 17. It is clear from the sample copy of the license and supply agreement filed before us that the product development charges received by the assessee will not be covered under clause 5(vii) of the DSIR guidelines. As we have alrea .....

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B/14 by the assessee is allowed, while ground No.2 raised by the revenue is dismissed. 18. Ground No.3 raised by the revenue reads as follows:- 3. The Ld CIT(A) erred in deleting the addition to book profit made by AO by adding the expenditure u/s 14A to the book profit. 19. The assessee, as we have already seen, is a company. Section 115JB of the Act provides that where in the case of an assessee being a company, the income tax payable on the total income as computed under the Act in respect of .....

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ted u/s. 115JB of the Act. 21. While computing the book profits for the purpose of sec. 115JB of the Act, the AO added to the net profits as per P&L account a sum of ₹ 66,56,821 which was the disallowance of expenses incurred by the assessee to earn income which does not form part of total income as laid down u/s. 14A of the Act. The quantum of sum so disallowed was added while computing the total income of the assessee under the normal provisions of the Act. This sum was also adopted .....

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nal grounds of appeal, has also referred to the enhancement of the book profit by the expenditure relating to exempt income of ₹ 66,56,821 worked out by the AO u/s.14A read with Rule 8D(2). The AO has not referred to any legal provision while enhancing the book profit by this amount but it appears to have been done keeping in mind clause (f) to explanation 1 of Sec.115JB of the Act where the expenditure relatable to any income to which Sec.10 (other than provision contained in clause 38 th .....

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s Act has been allowed to be adjusted by the IT Act, it has been done through very specific provisions in terms of the explanations to Sec. 115JB. When the language of the explanation is specific and unequivocal and mentions specific exempted incomes in explanation 1(f), there is no situation for reading in any other Interpretation even if they are analogous to the specified sections. While Sec.14A deals with disallowance of expenditure related to exempt income, it cannot be equated in letter an .....

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ubmissions. The ld. DR drew our attention to the provisions of section 115JB Explanation 1(f) and submitted that the amount of expenditure relatable to any income to which section 10 applies, should be added to the profit as per the P&L account. His submission was that section 14A of the Act r.w. Rule 8D of the Rules is a reasonable method of calculating the amount of expenditure and therefore without going into the question of whether Rule 14A can be imported into the provisions of clause ( .....

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hat section 115JB appears in Chapter XII-B of the Act dealing with specific provisions relating to certain companies and therefore those provisions cannot be applied. It was his further submission that even assuming that those provisions are applicable u/s. 115JB of the Act, it is only direct expenses that are contemplated as capable of being added to the profits as per P&L account. In this regard, our attention was drawn to the expression expenditure relatable used in sub-clause (f) of Expl .....

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The relevant provisions of Sec.115JB(2) and Explanation thereto need to be seen. The said provisions read thus: Sec.115JB:Special provision for payment of tax by certain companies. 115JB. (1) Notwithstanding anything contained in any other provision of this Act, where in the case of an assessee, being a company, the income-tax, payable on the total income as computed under this Act in respect of any previous year relevant to the assessment year commencing on or after the 1st day of April, 2012, .....

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sions of Part II of Schedule VI to the Companies Act, 1956 (1 of 1956); or (b) being a company, to which the proviso to sub-section (2) of section 211 of the Companies Act, 1956 (1 of 1956) is applicable, shall, for the purposes of this section, prepare its profit and loss account for the relevant previous year in accordance with the provisions of the Act governing such company: Provided that while preparing the annual accounts including profit and loss account,- (i) the accounting policies; (ii .....

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ancial year under the Companies Act, 1956 (1 of 1956)97b, which is different from the previous year under this Act,- (i) the accounting policies; (ii) the accounting standards adopted for preparing such accounts including profit and loss account; (iii) the method and rates adopted for calculating the depreciation, shall correspond to the accounting policies, accounting standards and the method and rates for calculating the depreciation which have been adopted for preparing such accounts includin .....

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rve specified under section 33AC; or (c) the amount or amounts set aside to provisions made for meeting liabilities, other than ascertained liabilities; or (d) the amount by way of provision for losses of subsidiary companies; or (e) the amount or amounts of dividends paid or proposed ; or (f) the amount or amounts of expenditure relatable to any income to which section 10 (other than the provisions contained in clause (38) thereof or section 11 or section 12 apply; or (g) the amount of deprecia .....

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he amount of income to which any of the provisions of section 10 (other than the provisions contained in clause (38) thereof)] or section 11 or section 12 apply, if any such amount is credited to the profit and loss account; or (iia) ….. (other portions of the section are not relevant for the present case) 27. A reading of the provisions of Sec.115JB(1) shows that when an Assessee is a company and the income-tax, payable on the total income as computed under this Act (under the normal pro .....

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net profit as shown in the profit and loss account for the relevant previous year prepared in accordance with the provisions of Part II of Schedule VI to the Companies Act, 1956 (1 of 1956). Expln.1 below Sec.115JB(2) also provides for certain additions and deductions from the said profit where such sums have either been added or reduced while arriving at the profit as per profit and loss account for the relevant previous year prepared in accordance with the provisions of Part II of Schedule VI .....

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wherein on identical order of CIT(A) and on identical facts and identical arguments by the Assessee and Revenue, this Tribunal held as follows:- 33. As far as ground No.3 is concerned, viz., the addition to the net profit as per profit and loss account expenditure incurred in earning income which does not form part of the total income under the Act, u/s.10 of the Act, it is seen that the quantum of expenditure disallowed by the AO by invoking the provisions of Sec.14A of the Act while computing .....

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been able to satisfy the AO regarding the quantum of expenditure incurred in earning income which does not form part of the total income under the Act. If the Assessee satisfies the AO regarding the quantum of expenditure incurred in earning income which does not form part of the total income under the Act than that can be adopted for the purpose of addition under clause (f) of Expln.1 below Sec.115JB(2) of the Act. Rule 8D of the rules come into play only when there is no other basis for arriv .....

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think that there is any prohibition to adopt the disallowance made by the AO u/s.14A of the Act read with Rule 8D of the rules, while computing total income under the normal provisions of the Act. The argument of the learned counsel for the Assessee that section 14A of the Act is very specific and is applicable only for the purpose of computing total income under Chapter IV of the Act and that section 115JB appears in Chapter XII-B of the Act dealing with specific provisions relating to certain .....

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ng of income which does not form part of the total income under the Act can be added under clause(f) of Expln.1 below Sec.115JB(2) of the Act, cannot be accepted. In our view, there is no difference between the expression expenditure relatable and the expression expenditure incurred by the Assessee in relation to . Both the expressions mean that whatever expenditure are incurred to earn income which does not form part of the total income under the Act, both direct and indirect expenditure, have .....

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lowance has been accepted by the Assessee. In such circumstances, we do not see any reason why the same disallowance cannot be adopted while arriving at the book profits u/s.115JB (2) of the Act read with Explanation 1(f) thereto. In our view the CIT(A) has fallen into an error in coming to a conclusion contrary. We therefore reverse the order the CIT(A) and restore the order of the AO in this regard. 29. In our view, the aforesaid decision will apply to the facts of the present case also, howev .....

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re and calls for no specific adjudication. 32. Ground No.2 raised by the assessee reads as follows:- 2. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the additions made by the assessing officer u/s. 14A read with rule 8D on the ground that the appellant has not produced the evidentiary support in relation to dispersal of loan and utilization of loan. Whereas the appellant has produced the evidence that the amount invested was out of positive bank balance and no borrowi .....

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and NSDL charges. It is thus clear that the assessee by implication had claimed that there was no expenditure incurred by way of interest, either directly or indirectly, which is attributable to the borrowed funds which were used for the purpose of investment which yielded tax free income. 35. The AO observed that Schedule G to the Financial Statements of the assessee had shown investment to the tune of ₹ 28,45,29,937 in shares mutual funds of various companies. He was of the view that suc .....

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t bearing loans were borrowed for specific purposes and not for investment purposes and in support of the above contention, the Assessee filed copies of balance sheets as on 31.03.2003 upto 31.03.2009 to show that the various loans availed from banks were all taken for specific purposes and could not have been utilized for making any investments out of which exempt income was earned. These loans include short term loans from IDBI Bank, Exim Bank, Barclays Bank and Standard Chartered Bank in resp .....

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the claim of the Assessee was not evidenced from the documents submitted in view of the loans and other sources of funds being mixed up in the common pool of funds. The CIT(A) further held that the burden of proof in this matter clearly continues to rest with the Assessee and that it was not enough to merely show that surplus funds were available or that bank loans had been availed for specific purposes including short term reasons. A one-to-one correlation must also be established to prove that .....

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copies as submitted. The CIT(A) also referred to the decision of Mumbai ITAT in the case of Hercules Hoists Ltd. (ITA No.7944, 7946, 2255 & 7943/mum/2011), wherein it was held that with the introduction of Rule 8D the burden of proof on the assessee has become more stringent, so that rather than showing existence of sufficient capital, the matter would be required to be examined from the stand point of utilisation of the borrowed interest bearing funds. In the absence of categorical utilisat .....

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this order. It is clear from the said statement that the availability of profit, share capital and reserves & surplus was much more than investments made by the assessee which could yield tax free income. 41. The Hon ble Bombay High Court in Reliance Utilities & Power Ltd. 313 ITR 340 (Bom) has held that where the interest free funds far exceed the value of investments, it should be considered that investments have been made out of interest free funds and no disallowance u/s. 14A towards .....

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n the present case of ₹ 49,42,473 made under Rule 8D(2)(ii) of the I.T. Rules should be deleted. We order accordingly. 43. As far as disallowance of ₹ 13,91,922 made by the AO under Rule 8D(2)(iii) of the Rules i.e., other expenses are concerned, we find that the assessee had made a claim before the AO that other expenses to be considered for disallowance under Rule 8D(2)(iii) is only ₹ 3,22,426. The assessee had also given a break-up of other expenses also. Without rejecting t .....

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of disallowance under Rule 8D(2)(iii) to the AO for fresh consideration in the light of observations made above, after affording assessee opportunity of being heard. Thus, ground No.2 raised by the assessee is allowed to the extent indicated above. 44. Ground No.3 raised by the assessee reads as follows:- 3. The learned Commissioner of Income Tax (Appeals) has erred in sustaining the addition regarding wealth tax liability under the provisions of section 115JB treating the provision for wealth t .....

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s under:- 5. The appellant has grieved against the AO adding the provision of Wealth Tax to the Book Profit u/s. 115JB whereas explanation 1(a) to Sec. 115JB only refers to the amount of income tax paid or payable, and the provision therefor. While agreeing with the appellant s view that wealth tax has not been specifically mentioned in this explanation, I nevertheless find that any provision for meeting liabilities other than ascertained liabilities is liable to be added back to book profit and .....

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