TMI Blog2006 (8) TMI 138X X X X Extracts X X X X X X X X Extracts X X X X ..... section 115JA(2) - bare perusal of the above Explanation (c) makes it clear that the increase shall be of the amount or amounts set aside for meeting liabilities other than ascertained liabilities. In the present case, there does not appear to be any dispute about the fact that the liability was ascertained. - since in our opinion, a reading of Explanation (c) of section 115JA(2) itself is very cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essing Officer has given absolutely no reason for increasing the book profits. Be that as it may, before the Commissioner of Income-tax (Appeals) the assessee contended that the book profits could not be increased in the manner as has been done by the Assessing Officer because of Explanation (c) under section 115JA(2) of the Act. This Explanation reads as follows:" For the purposes of this sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se 7(1)(a) thereof defines "provision" to mean any amount written off or retained, inter alia, by way of providing for any known liability of which the amount cannot be determined with substantial accuracy. So far as the present case is concerned, the accuracy has been determined fully, or at least there is no controversy about it. In any event, the occasion for resorting to the provisions of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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