TMI Blog2015 (12) TMI 1511X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 115JB, the petitioner adopted such amount of ₹ 4,23,47,912/- as shown in the profit and loss account. There were no additions and deductions to be made as referred to in Section 115JB and therefore, the final figure of book profit for the said provision came to the said original amount of ₹ 4,23,47,912/-. Thus for all purposes whether for the computation of income for normal tax provisions or as per the book profit under Section 115JB of the Act, the said amount of ₹ 15,458/- was duly reflected and was accounted for. The Assessing Officer formed wrong belief that for the purpose of computing book profit under Section 115JB of the Act, the said amount of ₹ 15,458/- disappeared from the consideration.Under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... worked out on book profit u/s.115JB. However, the same has not been added to work out book profit u/s.115JB. As such the dividend income of ₹ 15,458/- not considered for the working of tax liability on book profit u/s.115JB during the year under consideration is escaped income for the A.Y. 2010-11. In view of the above, I have reason to believe that the income chargeable to tax to the extent of ₹ 15,458/- has been assessed on account of failure on the part of the assessee to disclose fully and truly all material facts pertaining to the A.Y. 2010-11 and no opinion was formed in the original assessment. In view of above, I am of the opinion that this is a fit case for reassessment by invoking the provisions of Section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 47,912/-. This figure is significant and would appear in our later observations as well. In the profit and loss account, the petitioner showed dividend income of ₹ 15,458/- as income from other sources and showed profit before tax of ₹ 4,23,47,912/-. For computation of book profit for the purpose of Section 115JB, the petitioner adopted such amount of ₹ 4,23,47,912/- as shown in the profit and loss account. There were no additions and deductions to be made as referred to in Section 115JB and therefore, the final figure of book profit for the said provision came to the said original amount of ₹ 4,23,47,912/-. 8. Thus for all purposes whether for the computation of income for normal tax provisions or as per the book ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
