9911796707
TMI Blog2025 (4) TMI 991X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal, the assessee has raised the following grounds: - "1. In law and in the facts and circumstances of the appellant's case, the order passed by the learned CIT(A) u/s 250 of the Income-tax Act is void ab initio being bad in law. 2. In law and in the facts and circumstances of the appellant's case, Order u/s 143(1) is void-ab-initio since the Intimation order was passed without providing any opportunity of being heard about various addition made in the Order. 3. In law and on the facts and in the circumstances of the case of appellant, the Ld. CIT(A) has erred in upholding the addition of Rs. 558.55 crores on account of provision for taxation while computing book profit u/s 115JB instead of deleting entire adjustments made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8.55 crore as per the provisions of Explanation- 1 to Section 115-JB of the Act. Being aggrieved, the assessee is in appeal before us. 6. We have considered the submissions of both sides and perused the material available on record. As per the assessee, the amount of Rs. 578.79 crore was already added by the assessee to the book profit and the same was grouped under net expenses and shown under "Others" in Form ITR. As per the assessee, the amount of the current tax of Rs. 578.79 crore was already added after the netting of the tax adjustment of earlier years, i.e. Rs. 500.63 crore. Thus, as per the assessee, after reducing the tax adjustment of earlier years amounting to Rs. 500.63 crore, which were already offered to tax in the earlier y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 115-JB of the Act as supported by the report under Form No.29B issued by the independent Chartered Accountant, we find that the current tax liability of the assessee for the year under consideration was Rs. 78.16 crore while the deferred tax was amounting to Rs. 28.96 crore. Thus, the total tax expense was to the extent of Rs. 49.20 crore. 8. From the perusal of the intimation issued under section 143(1) of the Act, we find that the AO - CPC considered the entire amount of Rs. 578.79 crore as the income tax paid or payable by the assessee and added the same while computing the book profit under section 115-JB of the Act. Thus, it is evident that the amount of Rs. 500.63 being the tax adjustment of earlier years, which was disallowed i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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