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TMI Blog2019 (9) TMI 446X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 161,86,66,000/- being the reserve created for unexpired risk not to be added while computing the book profit under Section 115JB of the Income Tax Act, 1961 without considering the fact that Clause- (b) to explanation 1 of Section 115JB(2), book profit has to be increased by the said reserve? (ii) Whether on the facts and in the circumstances of the case the learned tribunal has erred in law ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case the learned tribunal has erred in law in holding that a sum of ₹ 87,78,52,000/- being the reserve created for unexpired risk should be considered as reserve for computing the book profit under Section 115JB of the Income Tax Act, 1961? ( b) Whether on the facts and in the circumstances of the case the learned tribunal has erred in law as well as on facts in holding ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considering the fact that Clause-(b) to explanation 1 of Section 115JB(2), book profit has to be increased by the said reserve? ( e) Whether on the facts and in the circumstances of the case conclusion arrived at by the tribunal in giving the aforesaid relief to the assessee is perverse? We admit this appeal on the following questions of law:- ( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... proposed against the above is not admitted. With regard to the proposed question (b), for the assessment years 2000-01 to 2009- 2010, either the appeals concerning this issue were not preferred before the tribunal or appeals were preferred and dismissed by the tribunal or no further step was taken by the revenue against the orders of the tribunal. So the issue is deemed to be closed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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