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TMI Blog2018 (2) TMI 2018X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER PER BENCH These four appeals are preferred by the revenue against the four separate orders passed by the Ld. CIT (Appeals) all dated 27th July, 2016 for A.Y. 2010-11, 2011-12, 2012-13 and 2013-14 and since a common issue involved therein, the same have been heard together and are being disposed of by a single consolidated order. 2. The solitary common issue involved in these fou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income under the normal provisions of the Act for all the four years under consideration. The said disallowance however was not added back by the assessee company while computing its book profit under section 115JB of the Act for all the four years under consideration. In the assessments completed under section 143(3)/153A for all the four years under consideration vide orders dated 31.03.2015, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the decisions of the Mumbai Bench of this Tribunal in the case of ACIT vs Spray Engineering Devices Ltd. ITA No. 6487/Mum/2004. Aggrieved by the orders of the Ld. CIT(A) giving this relief to the assessee, the revenue has preferred these appeals before the Tribunal. 5. We have heard the arguments of both the sides and also perused the relevant material available on record. It is observed that a s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4A of the Act. Hon'ble Kolkata High Court has further held that the computation of the amount of expenditure relatable to exempt income of the assessee must be made independently by applying clause (f) of Explanation (1) under section 115JB of the Act where the assessee has not claimed such expenditure to be nil. Respectfully following the said decision of the Hon'ble Jurisdictional High Court in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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