9911796707
TMI Blog2012 (7) TMI 937X X X X Extracts X X X X X X X X Extracts X X X X ..... CHOWLA, J.M. : This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)-II, Ludhiana dated 15.09.2011 relating to assessment year 2008-09 against the order passed u/s 143(3) of Income Tax Act, 1961 (in short 'the Act'). 2.The assessee had raised the following grounds of appeal: 1.That the Ld. CIT (A) erred in law and on facts in not deleting the additi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessing Officer and in view of Hon'ble Jurisdictional High Court's decision in the case of CIT Vs HERO CYCLES LTD reported in 323 ITR 518 (Pb.). 2.That the appellant craves, leave to add,amend, alter, modify or substitute all or any of the above mentioned Grounds of Appeal before the appeal is finally heard and disposed off. 3.The learned A.R. for the assessee pointed out that though t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 09. 4.The learned D.R. for the Revenue placed reliance on the orders of the authorities below. 5.We have heard the rival contentions and perused the record. The only issue arising in the present appeal is in respect of computation of book profits under section 115JB of the Act. The Assessing Officer while computing the said book profits had added back the disallowance worked out under section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llowing the ratio laid down by the Apex Court in Apollo Tyres Ltd. 255 ITR 273 (SC). We are in conformity with the order of CIT(A). The adjustments, if any, to be made to the profit shown in the profit and loss account, are provided in the section 115 JB of the Act itself. There is no provision in the Act to make adjustment on account of notional disallowance worked out under section 14A of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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