9911796707
TMI Blog2024 (11) TMI 849X X X X Extracts X X X X X X X X Extracts X X X X ..... rom record in the order of the Tribunal dated 19.07.2024 in observing that the assessee has agreed for the following issues to be remitted back to the AO:- "i. Addition made in respect of Reserve for Unexpired Risks (URR) u/s 115JB of the Act - page 27, para 16.2 of the order ii. Provision made towards Claims Incurred But Not Reported (IBNR) and Claims Incurred But Not Enough Reported (IBNER) added to the Book profits u/s 115JB of the Act - page 23, para 15.8 of the order. 2. The assessee has raised this mistake apparent from record in the order of Tribunal in para 16.3 at pages 28 & 29 and pointed out as under:- "Hence, taking a consistent view as agreed by both the learned counsels for assessee as well as Revenue, we remit this iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing Officer. Hence, this issue can be remitted back to the file of the Assessing Officer before whom the assessee will place all evidences and prove whether claim made by the assessee is ascertained liability or unascertained liability." 4. In term of the above, we rectify these mistakes in all these four miscellaneous applications MA Nos.61,67,66 & 65/CHNY/2024 of the assessee. 5. By way of this miscellaneous application, MA No.64/CHNY/2024 for the assessment year 2017-18, the assessee has requested for rectification of mistake apparent from record in the order of Tribunal as regards to amount of Rs. 1582.58 crores noted by the Tribunal in para 14 at page 15, the amount should be read as Rs. 1582.98 crores. 6. As regards to sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 143(3) of the Act while computing the income assessed included the adjustments proposed in the intimation u/s 143(1)(a) of the Act. b) the addition of Rs. 470,51,72,227/- made to the Book Profits u/s 11538 of the Act relating to Reserve for Unexpired Risk by the AO even though no amount had been debited to the Profit & Loss Account but there was only a credit (reversal) to the Profit and Loss Account of a similar amount 2. The Appellant therefore prays that the above additions/adjustments be deleted. 7.1 We have gone through the order of the Tribunal and noted that the Tribunal has not adjudicated these two additional grounds and hence, to that extent we recall the order of the Tribunal and direct the Registry to fix this appeal for th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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