CIT v. HCL Comnet Systems & Services Ltd.

305 ITR 409Supreme Court of India2008#901 most cited

What is CIT v. HCL Comnet Systems & Services Ltd. authority for?

For computing book profits under Section 115JB, an Assessing Officer's power is limited to examining duly certified books and making adjustments only as per the Explanation. A provision for bad and doubtful debts, being a diminution in the value of an asset (receivable), does not constitute a 'provision for liability' under Clause (c) of the Explanation and therefore cannot be added back.

118

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. HCL Comnet Systems & Services Ltd. · 305 ITR 409 · Section 115JB · Section 115JA · book profit calculation · provision for bad and doubtful debts · MAT adjustments · Assessing Officer jurisdiction · provision for liability · Explanation to Section 115JB(2) · diminution in asset value

Also reported as

174 Taxmann 118

Sections most often in play

Section 115JBSection 143(3)Section 14ASection 36(1)(vii)Section 135Section 194HSection 40(a)(ia)Section 115JA
Read the full judgment

Issues it is cited on

section 226section 115jasection 211section 14a(1)section 135section 115jb(2)explanation to section 37book profitsperiod of holdingsection 114section 115jsection 80hhc

Judgments citing CIT v. HCL Comnet Systems & Services Ltd.

Bilakhia Holding P Ltd, Vapi vs. The Jt.CIT., Vapi Range, Vapi

In the result, the appeal of the assessee is allowed for assessment year 2010-11

ITA 507/AHD/2013[2008-09]Status: DisposedITAT Surat04 Feb 2020AY 2008-09

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.507/Ahd/2013: िनधा"रण वष"/Assessment Year: 2008-09 आ.अ.सं/.I.T.A.No.1415Ahd/2015: िनधा"रण वष"/Assessment Year: 2009-10 आ.अ.सं/.I.T.A No.1416/Ahd/2015:िनधा"रण वष"/Assessment Year: 2010-11 आ.अ.सं/.I.T.A No.795/Ahd/2016: िनधा"रण वष"/Assessment Year: 2011-12 M/S. Bialkhia Holdings Pvt. Vs. Addl.Cit Range - Vapi / Ltd., Bilakhia House, Assistant Commissioner Of Muktanand Marg, Chala Income Tax Vapi Circle Vapi, Vapi, Gujarat. Shivam Commercial Complex, [Pan: Aadcs 4420 J] National Highway No.8, Vapi. अपीलाथ" Appellant ""यथ"/Respondent

Section 115JSection 143(3)Section 144C

…y excluding the provisions made for arrears or depreciation. The decision of the Apex Court has been followed in the following other decisions:- a. Malayala Manorama Co. Ltd vs. CIT [2008] 300 ITR 251 (SC) b. CIT vs. HCL Comnet Systems and Services Ltd [2008] 305 ITR 409 (SC), c. CIT-I Vs. Vijayashree Finance and Investment Co. Pvt. Ltd 2 DTR 38 [216 CTR (Madra) 191] d. CIT Vs. Rubamin P. Ltd [2009] 312 ITR 18 (Guj) e. CIT Vs. Kovai Maruthi Paper and Board P. Ltd [2007] 294 57 (Mad) f. CIT Vs. Adbhut Trading Co. P. Ltd [2011] 338 ITR 94 (Bom), and g. CIT Vs. Akshay Textiles Trading and Agencies P. Ltd [2008] 304…

DCIT, Gurgaon vs. M/S. Dlf Cyber City Developers Ltd., Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 3451/DEL/2017[2011-12]Status: DisposedITAT Delhi12 Dec 2019AY 2011-12
For Appellant: Sh. R. S. Singhvi, CAFor Respondent: Ms. Nidhi Srivastava, CIT DR
Section 801ASection 80ISection 9(2)

…regulatory boards in development schemes cannot be questioned by tax authorities. Reline in this behalf is placed on: - -ApolloTyres Vs. CIT (2002) 9 SCC 1(SC) -Malayala Manorama Co. Ltd Vs. CIT (2008) 12 SCC 612 (SC) -CIT Vs. HCL Commet System & Service Ltd. 305 ITR 409 (SC) -Marmo Classic Vs. Commissioner of Customs [2002 (143) ELT 153(Trib.--Mumbai] affirmed by Hon’ble Supreme Court in [2003 (152) ELT A85(SC)]; -Lokash Chemical Works Vs. M. S. Mehta 1981 (8) ELT 235; -Tital Medical System Pvt. Ltd. Vs. Collector 2003 (151) ELT 254 (SC) -CESTAT Judgment in Hico Enterprises Vs. Commissioner 2005-(189)ELT 135 (Tr…

DCIT, New Delhi vs. M/S Ircon International Ltd., New Delhi

In the result, all the three appeals of the assessee for A

ITA 3805/DEL/2008[2003-04]Status: DisposedITAT Delhi31 Oct 2019AY 2003-04

Bench: : Shri Bhavnesh Saini & Shri O.P. Kant

Section 80HSection 80I

…he circumstances of the case and without prejudice to ground no. 9(a) and 9(b) taken here in above, the Ld. CIT (A) was not justified in not taking into consideration the decision of the Supreme Court in the case of CIT V. HCL Comnet Systems & Services [2008] 305 ITR 409 , wherein it was held that the provision for bad and doubtful debts is not for meeting a liabilities is not to be included in the book profits for the purposes of sec. 115JB. 10.0 That on the facts and circumstances of the case the Ld. CIT (A) was not justified in rejecting the appellant's claim for provision for other expenses amounting to Rs. 4…

Ircon International Ltd., New Delhi vs. DCIT, Circle-11(1), Delhi

In the result, all the three appeals of the assessee for A

ITA 705/DEL/2006[2002-2003]Status: DisposedITAT Delhi31 Oct 2019AY 2002-2003

Bench: : Shri Bhavnesh Saini & Shri O.P. Kant

Section 80HSection 80I

…he circumstances of the case and without prejudice to ground no. 9(a) and 9(b) taken here in above, the Ld. CIT (A) was not justified in not taking into consideration the decision of the Supreme Court in the case of CIT V. HCL Comnet Systems & Services [2008] 305 ITR 409 , wherein it was held that the provision for bad and doubtful debts is not for meeting a liabilities is not to be included in the book profits for the purposes of sec. 115JB. 10.0 That on the facts and circumstances of the case the Ld. CIT (A) was not justified in rejecting the appellant's claim for provision for other expenses amounting to Rs. 4…

DCIT, Circle-11(1) vs. Ircon International Ltd

In the result, all the three appeals of the assessee for A

ITA 2234/DEL/2005[2001-2002]Status: DisposedITAT Delhi31 Oct 2019AY 2001-2002

Bench: : Shri Bhavnesh Saini & Shri O.P. Kant

Section 80HSection 80I

…he circumstances of the case and without prejudice to ground no. 9(a) and 9(b) taken here in above, the Ld. CIT (A) was not justified in not taking into consideration the decision of the Supreme Court in the case of CIT V. HCL Comnet Systems & Services [2008] 305 ITR 409 , wherein it was held that the provision for bad and doubtful debts is not for meeting a liabilities is not to be included in the book profits for the purposes of sec. 115JB. 10.0 That on the facts and circumstances of the case the Ld. CIT (A) was not justified in rejecting the appellant's claim for provision for other expenses amounting to Rs. 4…

Ircon International Limited, New Delhi vs. ACIT, New Delhi

In the result, all the three appeals of the assessee for A

ITA 3804/DEL/2008[2003-04]Status: DisposedITAT Delhi31 Oct 2019AY 2003-04

Bench: : Shri Bhavnesh Saini & Shri O.P. Kant

Section 80HSection 80I

…he circumstances of the case and without prejudice to ground no. 9(a) and 9(b) taken here in above, the Ld. CIT (A) was not justified in not taking into consideration the decision of the Supreme Court in the case of CIT V. HCL Comnet Systems & Services [2008] 305 ITR 409 , wherein it was held that the provision for bad and doubtful debts is not for meeting a liabilities is not to be included in the book profits for the purposes of sec. 115JB. 10.0 That on the facts and circumstances of the case the Ld. CIT (A) was not justified in rejecting the appellant's claim for provision for other expenses amounting to Rs. 4…

Ircon International Ltd vs. Addl. CIT, Range-11

In the result, all the three appeals of the assessee for A

ITA 1825/DEL/2005[2001-2002]Status: DisposedITAT Delhi31 Oct 2019AY 2001-2002

Bench: : Shri Bhavnesh Saini & Shri O.P. Kant

Section 80HSection 80I

…he circumstances of the case and without prejudice to ground no. 9(a) and 9(b) taken here in above, the Ld. CIT (A) was not justified in not taking into consideration the decision of the Supreme Court in the case of CIT V. HCL Comnet Systems & Services [2008] 305 ITR 409 , wherein it was held that the provision for bad and doubtful debts is not for meeting a liabilities is not to be included in the book profits for the purposes of sec. 115JB. 10.0 That on the facts and circumstances of the case the Ld. CIT (A) was not justified in rejecting the appellant's claim for provision for other expenses amounting to Rs. 4…

Tata Metaliks Limited, Kolkata vs. DCIT, Circle - 3(1), Kolkata

In the result, the appeal of the assessee is partly allowed

ITA 788/KOL/2018[2012-13]Status: DisposedITAT Kolkata04 Oct 2019AY 2012-13
For Appellant: Shri Ashish Agarwal &For Respondent: Shri Radhey Shyam, CIT
Section 115JSection 43B

…22 Taxman 562. But the fact remains that the propositions laid down by the hon'ble Supreme Court in the case of Apollo Tyres Ltd. (supra) have been reiterated and relied upon by the Supreme Court in the case of CIT v. HCL Comnet Systems & Services Ltd. [2008] 305 ITR 409/174 Taxman 118 which has been rendered in the context of section 115JA of the Act. As per sub-section (5) of section 115JB of the Act, which reads as "save as otherwise provided in this section, all other provisions of this Act shall apply to every assessee, being a company, mentioned in this section". Having regard to expression "save as otherwi…

DCIT, Circle - 3(1), Kolkata vs. M/S. Tata Metaliks Limited, Kolkata

In the result, the appeal of the assessee is partly allowed

ITA 1143/KOL/2018[2012-13]Status: DisposedITAT Kolkata04 Oct 2019AY 2012-13
For Appellant: Shri Ashish Agarwal &For Respondent: Shri Radhey Shyam, CIT
Section 115JSection 43B

…22 Taxman 562. But the fact remains that the propositions laid down by the hon'ble Supreme Court in the case of Apollo Tyres Ltd. (supra) have been reiterated and relied upon by the Supreme Court in the case of CIT v. HCL Comnet Systems & Services Ltd. [2008] 305 ITR 409/174 Taxman 118 which has been rendered in the context of section 115JA of the Act. As per sub-section (5) of section 115JB of the Act, which reads as "save as otherwise provided in this section, all other provisions of this Act shall apply to every assessee, being a company, mentioned in this section". Having regard to expression "save as otherwi…

Adani Agro Pvt. Ltd., Ahmedabad vs. The Dy.CIT., Circle-1, Ahmedabad

In the result, the assessee appeal is thus allowed

ITA 1809/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad20 Sept 2019AY 2009-10

Bench: Shri O. P. Meena& Ms. Madhumita Roy

For Appellant: Shri S. N. Soparkar, Sr. Advocate with Parin ShahFor Respondent: 17.09.2019
Section 115JSection 143(3)Section 14ASection 234BSection 234C

…that #?esaid provision for loan represents diminution in the value of asset being Lo3,~ itself and it 1$ not in the. nature of provision for unascertained liability. The Hon'bie Supreme Court in the case of CIT Vs HCL Comnet Systems & Services Ltd reported in 305 ITR 409 (SC) has held that a provision for diminution in the value of asset is not in the nature of provision for unascertained liability but represents reduction in (he value of asset and therefore, it is not required to be added while computing books profit u/$115JB of the I T Act* The assessee further replied as follows on 14.12.2011 in response to t…

Tata Services Ltd, Mumbai vs. ACIT 2(3)(2), Mumbai

In the result, this ground of appeal is also allowed for statistical purpose

ITA 50/MUM/2018[2014-15]Status: DisposedITAT Mumbai19 Sept 2019AY 2014-15

Bench: Shri G.S. Pannu & Shri Pawan Singhtata Services Ltd Vs Acit-2(3)(2), 24, Homi Mody Street Fort, Aayakar Bhawan, Mumbai 400 001 M.K.Road, Pan : Aaact3991J Mumbai-400020 Appellant Respondednt

Section 115JSection 143(3)Section 14ASection 244A

…e In the case of Ajanta Pharma vs. CIT 327 ITR 305(SC) where it was held by the Supreme Court that Section 115JB constitutes a complete code by itself, and the decision of Hon’ble Supreme Court in Apollo Tyres vs. CIT 255 ITR 273(SC) and HCL Comnet vs. CIT 305 ITR 409(SC), wherein it was held that while determining book profits under the MAT provisions, the Assessing Officer has to accept the authenticity of accounts which are prepared by the Company. The Assessing Officer is not empowered to embark upon a fresh enquiry in respect of the entries made in the books of account. The ratio of the above mentioned d…

Gloabal Mansions P.Ltd, Mumbai vs. ITO WD 2(1)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1192/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Sept 2019AY 2012-13

Bench: Shri Rajesh Kumar & Shri Amarjeet Singhassessment Year: 2012-13

For Appellant: Shri Manish Shah, A.RFor Respondent: Shri Chaudhary Arun Kumar Singh, D.R
Section 115JSection 143(1)Section 143(3)Section 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “G”, MUMBAI BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI AMARJEET SINGH, JUDICIAL MEMBER Assessment Year: 2012-13 M/s. Global Mansions P. ITO WD 2(1)(4), Ltd., Aayakar Bhavan, Now Merged with Lenient Mumbai - 400020 Finvest P. Ltd., Vs. Off No.2, 3rd Floor, Crescent Chambers, 56 Tamrind Lane, Fort, Mumbai – 400 023 PAN: AAACG1923H (Appellant) (Respondent) Present for: Assessee by : Shri Manish Shah, A.R. Ms. Niyanta Mehta, A.R. Revenue by : Shri Chaudhary Arun Kumar Singh, D.R. Date of Hearing : 17.07.2019 Date of Pronouncement : 13.09.2019 O R D E R…

Idbi Bank Ltd., Mumbai vs. ACIT (Ltu)-2, Mumbai

In the result this ground of appeal is

ITA 3423/MUM/2018[2008-09]Status: DisposedITAT Mumbai03 Sept 2019AY 2008-09

Bench: Shri R.C. Sharma & Shri Pawan Singh

Section 115JSection 143(3)Section 147Section 148Section 254(1)

…ion of Hon’ble Gujarat High Court in CIT Vs Vodafone Essar (Gujarat) Ltd (supra) wherein it is held that prior to the introduction of clause (i) to the Explanation to section 115JB, as held by the Supreme Court in case of HCL Comnet Systems & Services Ltd. (305 ITR 409 SC), the then existing clause (c) did not cover a case where the assessee made a provision for bad or doubtful debt. With insertion of clause (i) to the Explanation with retrospective effect, any amount or amounts set aside for provision for diminution in the value of the asset made by the assessee, would be added back for computation of book p…

Gts E-Services P.Ltd, Mumbai vs. ITO 15(1)(4), Mumbai

The appeal stands partly allowed

ITA 1231/MUM/2017[2012-13]Status: DisposedITAT Mumbai03 Jul 2019AY 2012-13

Bench: Hon’Ble Shri Pawan Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.1231/Mum/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Gts E-Services Private Ltd. Income Tax Officer-15(1)(4) 103, A-Wing Kensinton Room No.15B, Ground Floor बनाम/ Hiranandani Business Park Aaykar Bhavan, M.K. Road Vs. Hiranandani Builder Sez Mumbai-400 020. Powai, Mumbai-400 076. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccg-8662-R (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Nilesh Patel- Ld. Ar Revenue By : Shri V.K. Agarwal – Addl. Cit-Ld. Dr सुनवाई की तारीख/ : 26/06/2019 Date Of Hearing घोषणा की तारीख / : 03/07/2019 Date Of Pronouncement आदेश / O R D E R

For Appellant: Shri Nilesh Patel- Ld. ARFor Respondent: Shri V.K. Agarwal – Addl. CIT-Ld. DR
Section 115JSection 143(3)Section 144C(5)Section 92C

…Pvt. Ltd. V/s ITO [ITA No.64/Del/2015] coupled with the decisions of Hon’ble Supreme Court rendered in Apollo Tyres 255 ITR 273, Malayalam 10 GTS e-Services Private Limited Assessment Year :2012-13 Manorama 300 ITR 152 & HCL Comnet Systems and Services Ltd. 305 ITR 409. 8.2 After careful perusal of cited judicial decisions, we concur with the submissions made by Ld. AR. The relevant observations of co-oridnate bench of Mumbai Tribunal in Owens Corning (India) Pvt. Ltd. V/s DCIT [supra], for ease of reference, could be extracted in the following manner: - 4.1. The additional ground being purely legal and not req…

Alstom India Ltd, Mumbai vs. Addl CIT RG 1(1), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 6960/MUM/2014[2008-09]Status: HeardITAT Mumbai28 Jun 2019AY 2008-09

Bench: Shri Saktijit Deyand Shri G. Manjnatha

For Appellant: Shri Mrunal Parekh a/wFor Respondent: Shri Anadi Verma
Section 143(3)Section 147Section 35D

…year 2004–05. In addition, the learned Authorised Representative relied upon various other decisions, as referred to in the chart submitted before us, including the decision of the Hon'ble Supreme Court in CIT v/s HCL Comnet Systems and Services Ltd., [2008] 305 ITR 409 (SC). 13. We have considered rival submissions and perused the material on record. It is evident, the Assessing Officer taking recourse to clause (c) of Explanation–1 to section 115JB(2) of the Act has added back the provision for doubtful debts and advances to the book profit of the assessee. Reading of the aforesaid provision makes it clear th…

DCIT-2(1)(1), Mumbai vs. Bobcards Limited, Mumbai

Appeal stands partly allowed

ITA 4297/MUM/2017[2012-13]Status: DisposedITAT Mumbai07 May 2019AY 2012-13

Bench: Hon’Ble Shri Pawan Singh, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri H.N. Motiwala &For Respondent: Shri M.K. Singh - Ld.DR
Section 115JSection 143(3)Section 234BSection 234CSection 234D

…ty of the assessee. The attention was also drawn to the fact that Section 115JB was amended by the Finance (No.2) Act, 2009 with retrospective effect from AY 2001-02 in view of the decision of Apex Court rendered in CIT Vs. HCL Commet Systems & Services Ltd. [305 ITR 409]. By the amendment, clause (i) was added in Explanation 1 to Section 115JB with retrospective effect from AY 2001- 02. The said clause provided that the book profits were to be increased by the amounts set aside as provision for diminution in the value of any asset. Therefore, by virtue of the retrospective amendment, the aforesaid 5 provisions…

M/S Mindtree Ltd, Bangalore vs. The Commissioner of Income Tax Ltu, Bangalore

In the result, the appeal filed by the assessee is dismissed

ITA 424/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 Mar 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 10Section 10ASection 11Section 115JSection 12Section 142(1)Section 143(2)Section 143(3)Section 14ASection 154

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI ARUN KUMAR GARODIA, ACCOUNTANT MEMBER AND SHRI LALIET KUMAR, JUDICIAL MEMBER IT(TP)A No.424/Bang/2017 Assessment Year : 2012-13 M/s. Mindtree Ltd., The Commissioner of Global Village, RVCE Post, Income Tax, Mysuru Road, vs. Large Tax Payers Unit Bangalore – 560 059. (LTU), PAN: AABCM8839K Bangalore. APPELLANT RESPONDENT Assessee by : Shri Tata Krishna, Advocate Revenue by : Ms. Neera Malhotra, CIT (DR) Date of hearing : 14.03.2019 Date of Pronouncement : 29.03.2019 O R D E R Per Shri A.K. Garodia, Accountant Member This appeal is filed by t…

Catholic Syrian Bank Ltd, Trichur vs. The ACIT, Circle-1(1), Trichur

In the result, the appeal of the assessee is partly allowed for statistical

ITA 879/COCH/2004[1999-2000]Status: DisposedITAT Cochin20 Feb 2019AY 1999-2000

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

Section 115J

…fth issue is the provision for NPA amounting to Rs. 8,61,53,052/- for computing book profit under section 115J. The assessee contended that the decision of the Hon’ble Supreme Court in the case of CIT-IV, Delhi Vs. HCL Comnet Systems and Services Ltd. (2008), 305 ITR 409 (SC) is directly on the issue. On the other hand, the learned Departmental Representative relied on the orders of the authorities below . I.T.A. No.879/Coch/2004 10. On careful consideration of the rival submissions, we find that on identical set of facts, the Hon’ble Supreme Court in the case of HCL Comnet Systems and Services Ltd., cited supr…

DCIT, New Delhi vs. M/S Dlf Cyber City Developers Ltd., Gurgaon

ITA 4742/DEL/2015[2010-11]Status: DisposedITAT Delhi02 Jan 2019AY 2010-11

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

For Appellant: Shri R.S. Singhvi & Satyajeet Goel, CAsFor Respondent: Shri Shailesh Kumar, Senior DR
Section 80ISection 80l

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER and SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No.4742/Del./2015 (ASSESSMENT YEAR : 2010-11) DCIT, Circle 1 (1), vs. M/s. DLF Cyber City Developers Ltd., 3rd Floor, Shopping Mall, Gurgaon. Arjun Marg, DLF City, Phase – 1, Gurgaon. (PAN : AACCD3572H) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri R.S. Singhvi & Satyajeet Goel, CAs REVENUE BY : Shri Shailesh Kumar, Senior DR Date of Hearing : 06.12.2018 Date of Order : 02.01.2019 O R D E R PER KULDIP SINGH, JUDICIAL MEMBER : The appellant, DCIT, Circle…

The Dy. Commissioner of Income Tax Circle-1(1)(2), Ahmedabad vs. M/S. D.B. Corp. Ltd., Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 2880/AHD/2016[2007-08]Status: DisposedITAT Ahmedabad11 Dec 2018AY 2007-08

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr

For Appellant: Shri Mudit Nagpal, Sr. D.R
Section 115JSection 143(3)

…y the following judicial precedents: c. In respect of provision for deferred tax liability [illustrative]: • CIT v Balarampur Chini Mills Limited [316 ITR 374] [Cal] d. In respect of provision for doubtful debts/advances [illustrative]: • HCL Comnet Systems [305 ITR 409] [SC]; • Eicher Ltd [159 Taxman 293] [DEL]; • CIT v Hewlett Packard India Private Limited [314 ITR 55] [DEL] At the outset, it is submitted that the AO has not challenged/disallowed the (i) provision for deferred tax (ii) provision for doubtful debts and (iii) provision for doubtful advances on merits i.e. the additions/adjustments to the book pr…