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2023 (8) TMI 677

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..... - Shri Mahavir Singh, Vice President And Shri Manjunatha.G, Accountant Member For the Appellant : Shri D. Hema Bhupal, JCIT For the Respondent : Shri R. Viswanathan, FCA ORDER PER MAHAVIR SINGH, VICE PRESIDENT: This appeal by the Revenue is arising out of the order of the Commissioner of Income Tax (Appeals)-18, Chennai ITA No.33/CIT(A)-18/2020-21 dated 13.12.2022. The assessment was framed by the DCIT, Central Circle 1(2), Chennai for the assessment year 2018-19 u/s. 154 of the Income Tax Act, 1961 (hereinafter the Act ), vide order of dated 13.12.2022. 2. The only issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the addition made by the AO of comprehensive income while computing .....

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..... istent with the corresponding amounts entered in Schedule CG/Schedule OS and hence, the variance was Rs. 88,66,762 b. The claim of set-off of current year loss shown in Part B- TI is not consistent with the loss computed in the schedules of the corresponding heads of Income or the priority of set-off of the current year loss is not consistent with the provisions of the Act and hence the variance was Rs. 83,50,235. c. In Schedule MAT, there is an inconsistency in the computation of Book Profit from the amounts mentioned in Part A P L account and hence, the variance was Rs. 4,63,95,275. The assessee moved a rectification application with the CPC, Bangalore dated 26.06.2020 and the CPC, Bangalore rejected the rectification an .....

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..... from the computation of income filed before us that the variance in deemed total income to the book profit is below the line of profit before tax and this, as explained by the ld.counsel for the assessee before us now that the has revalued the investment and there is an increase in value of investments which is reported in the accounts only and this is purely notional or uncertain income because assessee has not earned any income on this account. We noted that the assessee also relied on the CBDT Circular No.24/2017 dated 25.07.2017 vide F.No.133/23/2015-TPL and subsequent issue of FAQ titled clarifications on computation of book profit for the purpose of levy of Minimum Alternate Tax (MAT) u/s. 115JB of the Act for Ind AS compliant compan .....

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