TMI Blog2023 (2) TMI 252X X X X Extracts X X X X X X X X Extracts X X X X ..... rvation of the Ld. PCIT is based upon the audit objection which has been replied by the assessee dated 10.11.2021 submitting therein that there is no mistake in making disallowance towards doubtful debts and computation of disallowance have duly been furnished in computation of taxable income. We also observe that the said figure of disallowance was arrived at on the basis of three amounts namely i) provisions for doubtful debts Rs. 55,03,00,000/-, ii) other provisions written back Rs. (- )39,10,00,000/- and iii) provisions for superannuation benefit of Rs. 33,04,58,000/- the net of which comes to Rs. 48,97,58,000/- which has been disallowed in the return of income filed by the assessee a copy of which is placed at page 39 of the PB. Acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d and against the provisions of the Act as the assessment framed is neither erroneous and nor prejudicial to the interest of the revenue. 3. Facts in brief are that the assessment was framed u/s 143(3) vide order dated 29.12.2019. The Ld. PCIT upon perusal of the said assessment records was of view that the assessment so framed was erroneous insofar as prejudicial to the interest of the revenue on two counts namely i) first wrong and excess credit of brought forward MAT to the tune of Rs. 1,47,76,76,957/- and ii) second ,the provisions made on account of doubtful debts amounting to Rs. 6,05,42,000/-was required to be added in computation to income which was not done. Accordingly the Ld. PCIT issued notice u/s 263 of the Act dated 17.03.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts amounting to Rs. 6,05,42,000/- on which the Ld. PCIT revised the assessment , we observe that there is no mistake in the computation of disallowance. We note that the said observation of the Ld. PCIT is based upon the audit objection which has been replied by the assessee dated 10.11.2021 submitting therein that there is no mistake in making disallowance towards doubtful debts amounting to Rs. 55,03,00,000/- and computation of disallowance of Rs. 48,97,58,000/- as per Note 29 and 34 have duly been furnished in computation of taxable income. We also observe that the said figure of disallowance was arrived at on the basis of three amounts namely i) provisions for doubtful debts Rs. 55,03,00,000/-, ii) other provisions written back Rs. (- ) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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