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TMI Blog2019 (5) TMI 19X X X X Extracts X X X X X X X X Extracts X X X X ..... ion by following the decision rendered by Hon ble Supreme Court in the case of Volkart Brothers [ 1971 (8) TMI 3 - SUPREME COURT] and CIT vs. RTCL Ltd. [ 2012 (4) TMI 287 - DELHI HIGH COURT] on the ground that when the issue is debatable section 154 cannot be invoked. Since the ld. CIT (A) has deleted the addition by following the settled principle of law that when issue is debatable on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rounds inter alia that :- 1. That on the facts and circumstances of the case in law, the Ld. CIT (A) has erred in deleting the addition of disallowance made u/s 14A to the book profit u/s 154 of the Income Tax Act, 1961. 2. That the order of ld. CIT (A) is erroneous and is not tenable on facts and in law. 2. Briefly stated the facts necessar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee has not preferred to put in appearance despite issuance of the notice and consequently, we proceeded to decide the present appeal with the assistance of the ld. CIT DR as well as on the basis of documents available on the file. 5. We have heard the ld. Departmental Representative for the revenue to the appeal, gone through the documents relied upon and orders passed by the reve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed the order on 07.11.2012 by making addition of ₹ 77,06,410/- u/s 14A in the normal computation but no such addition was made to the book profit. It is also not in dispute that taxable income as per the book profit has been claimed by the assessee at ₹ 1,90,67,455/- which was accepted by the AO. 8. However, subsequently AO has rectified its earlier order which was set ..... X X X X Extracts X X X X X X X X Extracts X X X X
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