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“book profits”

Special Rate ProvisionsSection 115JBSection 115JB1,713 judgments

The decision most relied on for book profits is Godrej & Boyce Mfg. Co. Ltd. v. DCIT (328 ITR 81), cited in 1,183 judgments on BharatTax.

Leading authorities on book profits

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

ACIT v. Vireet Investment Pvt. Ltd.
165 ITD 27 · 2017 · ITAT
882
citing judgments

No disallowance under section 14A can be made while computing book profits under section 115JB unless the expenditure is debited to the profit and loss account and satisfies clause (f) of Explanation 1 to section 115JB(2).

Joint Investments Pvt. Ltd. v. CIT
372 ITR 694 · 2015 · High Court
803
citing judgments

Disallowance under section 14A of the Income Tax Act cannot exceed the actual amount of exempt income earned by the assessee. This principle also applies when computing book profits under section 115JB.

ACIT v. Vireet Investment Pvt. Ltd.
82 Taxmann.com 415 · 2017 · High Court
789
citing judgments

Disallowance computed under Section 14A, read with Rule 8D, cannot be added to book profits under Section 115JB for Minimum Alternate Tax (MAT) purposes. Additionally, for Section 14A disallowance, only investments that yielded exempt income during the year are considered for calculating their average value.

Apollo Tyres Ltd. v. CIT
255 ITR 273 · 2002 · Supreme Court
657
citing judgments

For the purpose of computing book profits under Section 115J, arrears of depreciation, including those arising from assets working extra shifts, are a necessary charge on profits if debited to the profit and loss account and are allowable as such.

Kedarnath Jute Mfg. Co. Ltd. v. CIT
82 ITR 363 · 1971 · Supreme Court
654
citing judgments

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

CIT v. Yokogawa India Ltd.
341 ITR 385 · 2012 · High Court
270
citing judgments

A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.

Judgments citing book profits

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

Appeals are partly allowed

ITA 4158/MUM/2014[2007-08]Status: DisposedITAT Mumbai09 Nov 2023AY 2007-08

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 10(15)Section 115JSection 234BSection 41(4)Section 88ESection 90

adjustments, the assessing officer made other additions towards corporate tax computing the assessed income under normal provisions at Rs.39,69,74,66,800 and book profits under section 115JB of the Act at Rs.58,10,92,52,652. On further appeal the CIT(A) gave partial relief to the assessee ... have heard rival contentions and perused the material available on record. As could be seen in the return of income the assessee has computed book profit;.'under'..section 115JB at ₹720,47,89,971. The Assessing. Officer, while .completing, .the. assessment enhanced the book profit

Smt. Irvind Kaur Gujral, Jaipur vs. ITO, Ward-1(3), Jaipur

In the result, appeal of the assessee is dismissed

ITA 477/JPR/2023[2018-19]Status: DisposedITAT Jaipur09 Nov 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 5(1)(c)Section 90(3)

crores, and, provision for bad doubtful debts amounting to Rs. 5,359.64 crores in required to be excluded from the computation of book profits computed under section 11JB of the Act. Let us take up these two issues first, and then we will proceed to take up the remaining issues

Deputy Commissioner of Income Tax CC-7(3), Mumbai vs. M/S Macrotech Developers Limited (Formerly Known As Lodha Developers Pvt Ltd) (Successoer of M/S Bellissimo Crown Buildmart Pvt Ltd ), Mumbai

Accordingly should be allowed as a deduction

ITA 2383/MUM/2022[2016-17]Status: DisposedITAT Mumbai08 Nov 2023AY 2016-17

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 115JSection 14ASection 92C

Mum/2022 Mum/2022 Disallowance under section 14A Ground No.1 Ground No.1 Disallowance under section 14A of the Act Ground No.2 Ground No.2 while computing the book profit u/s 115JB of the Act Disallowance of depreciation on sample Flat Ground No.3 & 4 Capitalisation of foreign exchange loss to Ground No.5 work ... development. For the year under consideration, the assessee filed the return of income on 17/10/2016 declaring total income of Rs.62,08,53,170/- and book profit under section 115JB of Rs.45,42,04,660/-. Subsequently, the return was revised on 29/03/2018 declaring Nil income after setting off all brought forward

Deputy Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Macrotech Developers Limited, Mumbai

Accordingly should be allowed as a deduction

ITA 2382/MUM/2022[2016-17]Status: DisposedITAT Mumbai08 Nov 2023AY 2016-17

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 115JSection 14ASection 92C

Mum/2022 Mum/2022 Disallowance under section 14A Ground No.1 Ground No.1 Disallowance under section 14A of the Act Ground No.2 Ground No.2 while computing the book profit u/s 115JB of the Act Disallowance of depreciation on sample Flat Ground No.3 & 4 Capitalisation of foreign exchange loss to Ground No.5 work ... development. For the year under consideration, the assessee filed the return of income on 17/10/2016 declaring total income of Rs.62,08,53,170/- and book profit under section 115JB of Rs.45,42,04,660/-. Subsequently, the return was revised on 29/03/2018 declaring Nil income after setting off all brought forward

Indianoil Adani Ventures Limited (Formerly Known As "Indian Oiltanking Limited"), Mumbai vs. ITO - 10(3)(3), Mumbai

In the result, the appeals of the assessee in I

ITA 2402/MUM/2006[2002-2003]Status: DisposedITAT Mumbai06 Nov 2023AY 2002-2003

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Ms. Vasanti Patel a/w DeepaFor Respondent: Shri K.C Selvamani, CIT-DR
Section 115JSection 143(3)Section 144C(13)Section 14ASection 234D

disallowed the claim and added the amount back to the total income of the assessee. The AO also made the similar addition to the book profits computed under section 115JB of the Act. The Ld. CIT(A) relied on the decision in assessee’s own case ... submitted that the above decision of the Tribunal has upheld the decision of the CIT(A) to make adjustment of the amount disallowed to book profit under section 115JB of the Act. The Ld. AR prayed for a similar direction for the year under consideration. 8. The Ld. Departmental Representative

National Stock Exchange of India Ltd, Mumbai vs. DCIT, Cir-7(1)(1), Mumbai

In the result ground no.1 of the appeal of the assessee is allowed and grounds no

ITA 730/MUM/2023[2016-17]Status: DisposedITAT Mumbai26 Oct 2023AY 2016-17

Bench: Shri Aby T Varkey & Shri Amarjit Singhita Nos.730 & 731/Mum/2023 (A.Ys. 2016-17 & 2017-18) National Stock Exchange Vs. Dcit, Circle 7(1)(1) Of India Limited Room No. 126, 1 St Floor, Exchange Plaza, Bandra Aaykar Bhavan, Kurla Complex, Bandra M.K. Road, East, Mumbai – 400051 Churchgate -400 020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaacn1797L Appellant .. Respondent

For Appellant: Jehangir Mistri Sr. AdvFor Respondent: Srinivasu

reasons: 1. In the initial years, 25% of the profit after tax was transferred to provisions for contribution to Core SGF out of the book profits forthe year ended 31.3.2013 and 31.3.2014. 2. In the financial year ended 31.3.2016 the provisions made as above were reversed and credited

Cyqyator Media Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Central Circle-6(2)(1), Mumbai

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 2370/MUM/2023[2015-16]Status: DisposedITAT Mumbai23 Oct 2023AY 2015-16

Bench: Shri Vikas Awasthy& Shri Amarjit Singh आअसं.2370 /मुं/2023 (िन.व. 2015-16) Cyquator Media Services Private Limited, 18Th Floor, A Wing Marathon Futurex, N.M.Joshi Marg, Lower Parel, Mumbai – 400 013. Pan: Aaecp-0069-P ...... अपीलाथ"/Appellant बनाम Vs. Asstt.Commissioner Of Income Tax Central Circle – 6(2)(1), Mumbai Aaykar Bhavan, M.K.Road, Mumbai – 400 021 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Jay Bhansali "ितवादी "ारा/Respondent By : Shri Prabhat Kumar Gupta सुनवाई क" ितिथ/ Date Of Hearing : 18/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 23/10/2023 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi[ In Short ‘The Cit(A)’] Dated 21/06/2023, For The Assessment Year 2015- 16. 2. The Assessee In Appeal Has Raised As Many As Eight Grounds. All The Grounds Of Appeal Are In Respect Of A Single Issue I.E. Disallowance U/S. 14A Of 2 The Income Tax Act, 1961 [In Short ‘The Act’] R.W. Rule 8D Of The Income Tax Rules, 1962 [In Short ‘The Rules’].

For Appellant: Shri Jay BhansaliFor Respondent: Shri Prabhat Kumar Gupta
Section 14A

respect to disallowance u/s. 14A of the Act r.w.r. 8D is that disallowance made u/s. 14A of the Act should be disregarded while working book profits under MAT provisions. In support of his submissions, the ld. Authorized Representative of the assessee placed reliance on the decision in the case ... also the law expounded by Hon'ble Jurisdictional High Court. 8. Another prayer made by the assessee is with respect to the working of book profits u/s. 115JB of the Act disregarding disallowance made u/s. 14A of the Act. The Special Bench of the Tribunal in the case of Vireet

DCIT- 3(4), Mumbai vs. M/S Reliance Industries Limited, Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2588/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Oct 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

section 115JB(2) i.e. expenditure relating to exempt income, when no disallowance ought to have been made while computing book profit 4 Reliance Industries Ltd. AY 2017-18 & 2018-19 u/s 115JB the Act, relying on Tribunal decision in appellant's own case for AY 2009-10 vide corrigendum order ... dated 02.04.2008 Addition of interest on Income Tax Refund while computing Book Profits u/s 115JB 8. Erred in confirming the action of the learned AO of adding interest on income tax refund of Rs 181,17,790/- to the book profit of the appellant u/s 115JB

DCIT-3(4), Mumbai vs. M/S Reliance Industries Limited, Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2587/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

section 115JB(2) i.e. expenditure relating to exempt income, when no disallowance ought to have been made while computing book profit 4 Reliance Industries Ltd. AY 2017-18 & 2018-19 u/s 115JB the Act, relying on Tribunal decision in appellant's own case for AY 2009-10 vide corrigendum order ... dated 02.04.2008 Addition of interest on Income Tax Refund while computing Book Profits u/s 115JB 8. Erred in confirming the action of the learned AO of adding interest on income tax refund of Rs 181,17,790/- to the book profit of the appellant u/s 115JB

Reliance Industries Limited, Mumbai vs. Dy Commissioner of Income Tax Circle-3(4), Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2318/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

section 115JB(2) i.e. expenditure relating to exempt income, when no disallowance ought to have been made while computing book profit 4 Reliance Industries Ltd. AY 2017-18 & 2018-19 u/s 115JB the Act, relying on Tribunal decision in appellant's own case for AY 2009-10 vide corrigendum order ... dated 02.04.2008 Addition of interest on Income Tax Refund while computing Book Profits u/s 115JB 8. Erred in confirming the action of the learned AO of adding interest on income tax refund of Rs 181,17,790/- to the book profit of the appellant u/s 115JB

Reliance Industries Ltd., Mumbai vs. ACIT Circle 3(4), Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2317/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Oct 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

section 115JB(2) i.e. expenditure relating to exempt income, when no disallowance ought to have been made while computing book profit 4 Reliance Industries Ltd. AY 2017-18 & 2018-19 u/s 115JB the Act, relying on Tribunal decision in appellant's own case for AY 2009-10 vide corrigendum order ... dated 02.04.2008 Addition of interest on Income Tax Refund while computing Book Profits u/s 115JB 8. Erred in confirming the action of the learned AO of adding interest on income tax refund of Rs 181,17,790/- to the book profit of the appellant u/s 115JB

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited & Adity Birla Minacs Worldwide Limited ), Mumbai vs. Joint Commissioner of It (OSD)10(2)(2)Assistant Commissioner of Income Tax-9(2)(2), Mumbai

ITA 5764/MUM/2017[2012-13]Status: DisposedITAT Mumbai18 Oct 2023AY 2012-13
For Appellant: Shri Yogesh TharFor Respondent: Shri Ajit Pal Singh Daia
Section 143(3)Section 144C(3)Section 92(1)Section 92B

Profit and Loss Account. Other may book the loss in the Profit and Loss Account which may result in the reduction of book profit. In cases where no sale or settlement has actually taken place and the loss on Marked to Market basis has resulted in reduction of book profits

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited & Adity Birla Minacs Worldwide Limited ), Mumbai vs. Deputy Commissioner of Income Tax-10(2)(2), Mumbai

ITA 5260/MUM/2017[2011-12]Status: DisposedITAT Mumbai18 Oct 2023AY 2011-12
For Appellant: Shri Yogesh TharFor Respondent: Shri Ajit Pal Singh Daia
Section 143(3)Section 144C(3)Section 92(1)Section 92B

Profit and Loss Account. Other may book the loss in the Profit and Loss Account which may result in the reduction of book profit. In cases where no sale or settlement has actually taken place and the loss on Marked to Market basis has resulted in reduction of book profits

Chandhok Cold Storage Pvt. Ltd., Raipur vs. Income Tax Officer, Ward-3(1), Raipur

In the result, the appeal of the assessee is partly allowed for statistical purposes in terms of the aforesaid observations

ITA 200/RPR/2023[2013-14]Status: DisposedITAT Raipur18 Oct 2023AY 2013-14

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 200/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Chandhok Cold Storage Private Limited Ph No.100/28, Bilaspur Road, Ravigram S.O, Raipur-492 001 Pan : Aadcc8354P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Hardik Jain, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 224Section 56Section 56(2)(viib)

claimed as refund under the Income-tax Act, to the extent of the excess over the tax payable with reference to the. book profits in accordance with the law applicable thereto; (iv) any amount representing provisions made for meeting liabilities, other than ascertained liabilities; (v) any amount representing contingent liabilities ... claimed as refund under the Income-tax Act, to the extent of the excess over the tax payable with reference to the book profits in accordance with the law applicable thereto; (v) any amount representing provisions made for meeting liabilities, other than ascertained liabilities: (vi) any amount representing contingent liabilities

DCIT (Central Circle -6(3), Mumbai vs. Karanja Terminal & Logistics Pvt Ltd, Mumbai

In the result, the appeals of the Revenue are dismissed

ITA 2159/MUM/2023[2016-2017]Status: DisposedITAT Mumbai16 Oct 2023AY 2016-2017

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 115J

section 2(24) of The Income Tax Act, 1961. Since it does not enter into computation provisions of Act, it cannot be included in book profit as per scheme of provisions of section 115 JB. 10 ITAs 2158 & 2159/Mum/2023 Karanja Terminal & Logistics Pvt Ltd  In the case of DCIT Circie ... successful trial run of the final-acceptance by the customer .Therefore, the retention money cannot be regarded as income even for the purpose of book profits u/s. 115JB of the Income Tax Act, 1961.  In the case of ACIT, Range-2, V/s. M/s. L. H. Sugar Factory Ltd., ITA NQ.417

DCIT (Central Circle -6(3), Mumbai vs. Karanja Terminal & Logistics Pvt Ltd, Mumbai

In the result, the appeals of the Revenue are dismissed

ITA 2158/MUM/2023[2017-18]Status: DisposedITAT Mumbai16 Oct 2023AY 2017-18

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 115J

section 2(24) of The Income Tax Act, 1961. Since it does not enter into computation provisions of Act, it cannot be included in book profit as per scheme of provisions of section 115 JB. 10 ITAs 2158 & 2159/Mum/2023 Karanja Terminal & Logistics Pvt Ltd  In the case of DCIT Circie ... successful trial run of the final-acceptance by the customer .Therefore, the retention money cannot be regarded as income even for the purpose of book profits u/s. 115JB of the Income Tax Act, 1961.  In the case of ACIT, Range-2, V/s. M/s. L. H. Sugar Factory Ltd., ITA NQ.417

Deputy Commissioner of Income Tax (Central-1), Raipur vs. M/S Sunil Sponge Pvt. Ltd., Raipur

In the result, the appeal of the revenue is dismissed in terms of our aforesaid observations

ITA 73/RPR/2022[2007-08]Status: DisposedITAT Raipur12 Oct 2023AY 2007-08

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.73/Rpr/2022 "नधा"रण वष" / Assessment Year : 2007-08 The Deputy Commissioner Of Income Tax, (Central Circle)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunil Sponge Pvt. Ltd. H. No.11, Jalvihar Colony, Raipur (C.G.)-492 001 (C.G.) Pan : Aahcs7999A ……""यथ" / Respondent

For Appellant: S/shri, Sakshi Gopal Agrawal &For Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 143(3)Section 147Section 148Section 40A(2)(b)

Petitioner to show cause why the amount of Rs. 47.04 crores being claimed as book depreciation on intangibles should not be disallowed to determine book profits under Section 115JB of the Act. The above query of the Assessing Officer was responded to by the Petitioner in great detail ... support of its contention that they are entitled to deduction of the current years depreciation from the net profit to arrive at the book profits under Section 115JB of the Act. It 12 DCIT (Central Circle-1), Raipur Vs. M/s. Sunil Sponge Pvt. Ltd. was also explained that under subsection

Polygel Industries Private Limited, Mumbai vs. Principle Commissioner of Income Tax, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 1971/MUM/2023[2018-2019]Status: DisposedITAT Mumbai11 Oct 2023AY 2018-2019

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blepolygel Industries Pvt. Ltd., V. Pcit – Mumbai – 2 321, The Great Eastern Galleria Aayakar Bhavan, M.K. Road Plot No. 20, Sector – 4 Mumbai - 400020 Nerul (West), Navi Mumbai Thane - 400706 Pan: Aaack4105F (Appellant) (Respondent) Assessee Represented By : Shri Himanshu Gandhi Department Represented By : Shri K.C. Selvamani

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 263Section 36(1)(vii)Section 43B

income under normal provision at Rs.50,67,670/-. 2. On perusal of the case records, it is noticed that in the computation sheet the book profit was shown at Rs.68,53,323/-, however the correct book profit after incorporating the addition/disallowance of the assessment order ... contended that computation u/s 115JB is correctly made and there is no error in it. The assessee also expressed surprise on the figure of Book Profits at ₹.1,80,91,596/- mentioned for the above said notice as the same is not appearing in the profit and loss account

Asst CIT 6 (2)(1), Mumbai vs. M/S Chiripal Poly Films Ltd., Mumbai

ITA 258/MUM/2020[2014-15]Status: DisposedITAT Mumbai11 Oct 2023AY 2014-15
For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri K.C. Selvamani
Section 115JSection 143(3)Section 56(2)(viib)Section 68

facts and circumstances of the appellant's case, Hon'ble ITAT may direct the Ld. Assessing officer to reduce the book profit computed under section 115JB by the 3 CO No.152/Mum/2022 (Assessment Year: 2014-15) capital receipt received by the assessee during the year under consideration in the form ... facts and circumstances of the appellant's case, Hon'ble ITAT may direct the Ld. Assessing officer to reduce the book profit computed under section 115JB by a capital receipt received by the assessee during the year under consideration in the form of MEIS/SEIS incentive

ACIT Circle-15(2), New Delhi vs. Lifestyle Probuild Pvt Ltd, Ghaziabad

In the result, this appeal by the Revenue stands dismissed

ITA 3552/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Oct 2023AY 2015-16

Bench: AO; that valuation report dated 15.03.2012 prepared by the Chartered Accountant as per rule 11UA

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Ms. Jyoti Verma, Sr. DR
Section 56(2)(viib)

claimed as refund under the Income-tax Act, to the extent of the excess over the tax payable with reference to the book profits in accordance with the law applicable thereto; (iv) any amount representing provisions made for meeting liabilities, other than ascertained liabilities; (v) any amount representing contingent liabilities ... claimed as refund under the Income-tax Act, to the extent of the excess over the tax payable with reference to the book profits in accordance with the law applicable thereto; (iv) any amount representing provisions made for meeting liabilities, other than ascertained liabilities; (vi) any amount representing contingent liabilities