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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

The Assistant Commissioner of Income-Tax-2(1)Bhilai, Bhilai(Cg) vs. M/S Sms Shivnath Infrasstructure Pvt Ltd., Durg, Durg(Cg)

In the result, appeal of the revenue in ITA No

ITA 87/BIL/2017[2012-13]Status: DisposedITAT Raipur27 Mar 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

Assessing Officer ("AO") including furnishing of statutory form 10CCB in support of deduction claimed U/s 80lA as well as the computation of book profits U/s 115JB of the Act. The assessment was completed U/s .143(3) of the Act by making an addition of Rs. 13,90,58,404 representing ... Accordingly, even in AY 2011-12, the Assessee had added back the proportionate interest attributable to the interest-free advances given to its book profit in the computation of income to arrive at the eligible profit under section 801A. 13.7.3. The said calculation was approved by the AO in scrutiny

M/S Sms Shivnath Infrastructure Pvt Ltd, Durg(Cg) vs. The Pr. Commissioner of Income Tax-2, Raipur (Cg)

In the result, appeal of the revenue in ITA No

ITA 107/BIL/2016[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

Assessing Officer ("AO") including furnishing of statutory form 10CCB in support of deduction claimed U/s 80lA as well as the computation of book profits U/s 115JB of the Act. The assessment was completed U/s .143(3) of the Act by making an addition of Rs. 13,90,58,404 representing ... Accordingly, even in AY 2011-12, the Assessee had added back the proportionate interest attributable to the interest-free advances given to its book profit in the computation of income to arrive at the eligible profit under section 801A. 13.7.3. The said calculation was approved by the AO in scrutiny

Dcm Shriram Industries Limited, New Delhi vs. ACIT, Circle-7(1), Delhi

In the result, the appeals are partly allowed

ITA 1000/DEL/2022[2017-18]Status: DisposedITAT Delhi15 Mar 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

Another off-shoot of this issue is whether the receipts from RECs, being in the nature of capital receipts, will form part of book profit computed under section 115JB of the Act. We find, this issue has also been addressed by the Coordinate Bench in case ... Once a particular receipt is treated as capital receipt, the same cannot be brought to tax in garb of ‘minimum alternative tax’ applicable on book profits computed u/s 115JB of the Act. The ratio of judgment delivered by the Hon’ble High Court of Calcutta in case of Ankit Metal

Dcm Shriram Industries Ltd, New Delhi vs. Addi. CIT National E - Assesment Centre, New Delhi

In the result, the appeals are partly allowed

ITA 539/DEL/2021[2016-17]Status: DisposedITAT Delhi15 Mar 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

Another off-shoot of this issue is whether the receipts from RECs, being in the nature of capital receipts, will form part of book profit computed under section 115JB of the Act. We find, this issue has also been addressed by the Coordinate Bench in case ... Once a particular receipt is treated as capital receipt, the same cannot be brought to tax in garb of ‘minimum alternative tax’ applicable on book profits computed u/s 115JB of the Act. The ratio of judgment delivered by the Hon’ble High Court of Calcutta in case of Ankit Metal

Dcm Shriram Industries Ltd, New Delhi vs. Addi. CIT Special Range-3, New Delhi

In the result, the appeals are partly allowed

ITA 1841/DEL/2020[2015-16]Status: DisposedITAT Delhi15 Mar 2023AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2017-18 With Assessment Year 2016-17 With Assessment Year 2015-16

Section 133(6)Section 80I

Another off-shoot of this issue is whether the receipts from RECs, being in the nature of capital receipts, will form part of book profit computed under section 115JB of the Act. We find, this issue has also been addressed by the Coordinate Bench in case ... Once a particular receipt is treated as capital receipt, the same cannot be brought to tax in garb of ‘minimum alternative tax’ applicable on book profits computed u/s 115JB of the Act. The ratio of judgment delivered by the Hon’ble High Court of Calcutta in case of Ankit Metal

M/S Jaipur Telecom Pvt. Ltd., Jaipur vs. Pr. CIT-2, Jaipur

In the result, appeal of the assessee is allowed

ITA 274/JPR/2021[2014-15]Status: HeardITAT Jaipur14 Mar 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No.274/JPR/2021 fu/kZkj.ko"kZ@Assessment Years :2014-15 M/s Jaipur Telecom Pvt. Ltd. 3, Amrapali Circle, Vaishali Nagar, Jaipur. cuke Vs. Pr.CIT-2, Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCJ 0763 D vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby :Sh. Manish Agarwal(C.A.) jktLo dh vksjls@Revenue by: Sh. Ajey Malik (CIT) lquokbZ dh rkjh[k@Date of Hearing : 15/02/2

For Appellant: Sh. Manish Agarwal(C.A.)For Respondent: Sh. Ajey Malik (CIT)
Section 143(3)Section 263

case and in law Id. PCIT-2, Jaipur has grossly erred in issuing direction for revision of completed assessment for re computing the Book Profit u/s 115JB of the Income Tax Act. Appellant prays that Book profit declared by assessee is in accordance with law and deserves to be accepted ... material available on record, the Assessing Officer failed to consider/apply his mind to the information available on record with regard to the calculation of book profit u/s 115JB. Thus the order passed on 28-12- 2016 is without making necessary verification of the income determined under section 115JB and without

Pvr Pictures Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3843/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

For Appellant: Shri V.K. Garg, Adv. & Shri ParveenFor Respondent: Ms. Beenu, Sr.DR
Section 115JSection 143(3)

assessee has challenged the computation of adjustment allowable in terms of clause (iii) of Explanation-1 to Section 115JB(2) for computation of book profits made by the Assessing Officer resulting in lower adjustment to the extent of Rs.93,06,502/-. 3. When the matter was called for hearing ... assessee submitted that; I.T.As. No.3843/Del/2017 2 (i) the assessee furnished its return of income computing total income under normal provisions of the Act. Likewise, book profit under Section 115JB was also computed at Nil. In the course of the assessment proceedings, the book profit was re-determined by the assessee

Shri Prashantsinh Ajitsinh Chauhan, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 123/RJT/2022[2017-18]Status: HeardITAT Rajkot24 Feb 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri R.K. Doshi, Ld. A.RFor Respondent: Shri Shramdeep Sinha, Ld. CIT-D.R
Section 143(3)Section 263

Mills Co. Ltd. v. CIT [IT Appeal no. 1013 & 1635 (Pun.) of 2015, made the following observations: "40. Now, coming to the aspect of book profits which was considered by the Commissioner and the order of the Assessing Officer was held to be erroneous and prejudicial to the interest ... other than the aspect for which it is picked up. Hence, the Assessing Officer has not formed any opinion in respect of computation of book profits in the hands of assessee. Once, no such opinion has been formed by the Assessing Officer, the Commissioner has erred in holding the order

Srf Ltd., Gurgaon vs. Addl CIT, New Delhi

In the result, this ground of the assessee is allowed for statistical purposes

ITA 774/DEL/2017[2009-10]Status: DisposedITAT Delhi23 Feb 2023AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Ussrf Limited Vs. Acit Unitech Crest, Greenwood Range – 9, City Block – C, Sector – 45, Ltu, New Delhi Gurgaon – 122 003 Pan No. Aaacs 0206 P (Appellant) (Respondent) Assessee By Shri Pradeep Dinodia, Shri R. K. Kapoor C.A. Shri Ravi Kumar Revenue By Shri Mahesh Shah, Cit (Dr) Shri Rajesh Kumar, Cit (Dr) Date Of Hearing: 10/01/2023 Date Of Pronouncement: 23/02/2023 Order Per Anil Chaturvedi, Am: The Present Appeal Is Filed By The Assessee Directed Against The Order Dated 27.09.2016 Of The Commissioner Of Income Tax (Appeals)-44, New Delhi [For Short, Cit(A)] Under Section 143(3) R.W.S 144C Of The Income Tax Act, 1961 [For Short, 'The Act'] For Assessment Year 2009-10. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under:-

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

Certified Emission Reduction (CER’s) /“Carbon credits” amounting to Rs 3,48,37,38,617/- may held to be excluded from the computation of “book profits” u/s 115JB of the Income Tax Act, 1961” 8. With respect to the admission of additional grounds, it is submitted that the additional grounds ... submitted that the Hon’ble Tribunal has further held that since the receipt is capital in nature it cannot be considered while computed the book profits u/s 115JB of the Act. He, therefore, submitted that following the order in assessee’s own case for A.Y. 2006-07, the issue

Viswanathan Securities P.Ltd, New Delhi vs. ACIT, Circle-26(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 135/DEL/2019[2010-11]Status: DisposedITAT Delhi21 Feb 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri R.K. Mehra, CAFor Respondent: Shri N.K. Bansal, Sr.DR
Section 143(3)Section 147Section 148Section 148(1)Section 292B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F” DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER & SHRI PRADIP KUMAR

ACIT, Central Circle- 27, New Delhi vs. A.R. Leasing Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 9239/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Feb 2023AY 2015-16

Bench: Sh. Anil Chaturvedi & Sh. Narender Kumar Choudharyacit Vs. A. R. Leasing Pvt. Ltd. Central Circle – 27, 305, 3Rd Floor, Bhanot New Delhi Corner, Pampost Enclave, Greater Kailash-1, New Delhi-110 048 Pan No. Aaaca 0423 A (Appellant) (Respondent) Assessee By Shri M. P. Rastogi, Adv. & Shri Rajeev Kumar, C.A. Revenue By Shri Kanav Bali, Sr. D.R. Date Of Hearing: 06.01.2023 Date Of Pronouncement: 16.02.2023 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Revenue Is Directed Against The Order Dated 24.09.2019 Passed By The Commissioner Of Income Tax (Appeals)-31, New Delhi Relating To Assessment Year 2015-16. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under:-

Section 115JSection 143(3)Section 14ASection 68

framed u/s 143(3) of the Act vide order dated 26.12.2017 and the total taxable income was determined at Rs.6,87,88,620/- and book profit u/s 115JB of the Act was assessed at Rs.1,09,33,440/-. 4. Aggrieved by the order of AO, assessee carried the matter before ... Whether on the facts and in the circumstances and in the law the Ld CIT(A) is justified in deleting the addition to book profit and terms of clause (f) of para 1 to Explanation to Section 115JB of the Act. 3. Whether on the facts and in the circumstances

DCIT, Central Circle- 7, New Delhi vs. Pepsico India Holdings Pvt. Ltd., Gurgaon

In the result, the appeal of the Revenue is partly allowed for statistical purposes

ITA 3231/DEL/2019[2009-10]Status: DisposedITAT Delhi14 Feb 2023AY 2009-10

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2009-10 Dcit, Central Vs. Pepsico India Holdings Pvt. Ltd. Circle-7, Level 3-6, Pioneer Square, New Delhi. Sector-62, Near Golf Course Pin 110 055 Extension Road, Gurgaon, Haryana Pin 122 001. (Appellant) (Respondent)

For Appellant: Shri K.M. Gupta, AdvFor Respondent: Shri Vivek Vardhan, Sr.DR
Section 115JSection 143(1)Section 143(3)Section 14A

restricting the addition upto Rs. 1,69,88,579/- made by the AO on account of disallowances u/s 14A r.w.r.8D under book profit u/s 115JB of the Act. 5. On the facts and circumstances of the case, the Ld. CIT(A) has erred in law in deleting the addition ... made by the AO on account of disallowances of depreciation on computer peripherels as well as book profit u/s 115JB. 6. On the facts and circumstances of the case, the Ld. CIT(A) has erred in law in deleting the addition of Rs. 43,63,385/- made

M/S Hanuman Tube Well Co., Jaipur vs. Deputy Commissioner of Income Tax, Circle-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 865/JPR/2019[2008-09]Status: DisposedITAT Jaipur13 Feb 2023AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.L. Jain (Adv.) &For Respondent: Shri Sanjay Dhariwal (CIT)
Section 143(2)Section 147Section 148Section 40

facts of the case. Relief may please be granted by quashing the re-assessment proceedings being illegal and without any basis. 2. Re-computing book profit for the purpose of remuneration:- That on the facts and in the circumstances of the case Ld. CIT(A), Kota has grossly erred ... facts in confirming the actions of the ld. AO inre-computing book profit for the purpose of section 40(b) in relation to remuberation to partners. 3. That the AO has no power to reopen the completed assessments merely for a change of opinion:- Where the primary facts necessary

ACIT Circle 25-(1), Delhi vs. Value First Digital Media Pvt. Ltd., Gurgaon Haryana

In the result, ITA No. 3143/Del/2019 [A

ITA 2050/DEL/2021[2014-15]Status: PendingITAT Delhi08 Feb 2023AY 2014-15

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

company's account may not tally with taxable profits. This does not mean that the AO would substitute the taxable profits with book profits on his own. This is possible only as per the scheme of the act. Since, the provisions of income tax act for allowing

ACIT, Circle-26(1), New Delhi vs. Value First Digital Media Pvt. Ltd., New Delhi

In the result, ITA No. 3143/Del/2019 [A

ITA 5127/DEL/2019[2016-17]Status: DisposedITAT Delhi08 Feb 2023AY 2016-17

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

company's account may not tally with taxable profits. This does not mean that the AO would substitute the taxable profits with book profits on his own. This is possible only as per the scheme of the act. Since, the provisions of income tax act for allowing

ACIT, Circle-26(1), New Delhi vs. Value First Digital Media Pvt. Ltd., New Delhi

In the result, ITA No. 3143/Del/2019 [A

ITA 3143/DEL/2019[2012-13]Status: DisposedITAT Delhi08 Feb 2023AY 2012-13

Bench: Shri Narender Kumar Choudhry & Dr. B.R.R. Kumar

Section 250Section 40Section 72ASection 9(1)(vi)

company's account may not tally with taxable profits. This does not mean that the AO would substitute the taxable profits with book profits on his own. This is possible only as per the scheme of the act. Since, the provisions of income tax act for allowing

DCIT, C-11(1), New Delhi vs. Hero Motocorp Ltd., New Delhi

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

unascertained liability on account of provision for advertisement expenses.’ Therefore, it would be noted that no qualification was made by the auditors to the ‘book profit’ as shown in the P&L account of the company. Reliance is placed on the following decisions, wherein it has been held that provision ... basis or on the basis of actuarial valuation, etc., will not be regarded as provision for unascertained liability, liable to be added back to ‘book profits’ under section 115JB of the Act: - CIT vs. H.P. Tourism development Corpn. Ltd: 217 Taxman 148 (HP) - ACIT vs. NHPC

Cj Darcl Logistics Limited, Haryana vs. Circle 7(1), Delhi

In the result, the appeal is treated as allowed for statistical purposes

ITA 288/DEL/2022[2015-16]Status: DisposedITAT Delhi27 Jan 2023AY 2015-16

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2015-16

For Appellant: Shri Anubhav Rastogi, AdvocateFor Respondent: Shri Vipul Kashyap, Sr. DR
Section 115JSection 143(1)Section 234B

year relevant to the assessment year commencing on or after the 1st day of April, 2010, is less than fifteen per cent of its book profit, such book profit shall be deemed to be the total income of the assessee and the tax payable by the assessee on such total ... provisions of Parts II and III of Schedule VI to the Companies Act, 1956 (1 of 1956)" The above section clearly talks that such book profit shall be deemed to be total income of the assessee and tax payable by the assessee on such total income shall be the amount

Haier Appliances India P.Ltd, New Delhi vs. ACIT, Circle-11(1), New Delhi

ITA 1458/DEL/2022[2015-16]Status: DisposedITAT Delhi24 Jan 2023AY 2015-16
Section 115JSection 143(3)Section 250Section 37(1)

lower of the brought forward business loss and unabsorbed depreciation as per books of account amounting to Rs.18,72,10,467/-, while computing book profits under section 115JB of the Act. The appellant craves leave to ad to, alter, amend or vary from the above grounds of appeal before

Srf Limited, New Delhi vs. ACIT, Circle- 1, Ltu, New Delhi

ITA 5892/DEL/2019[2008-09]Status: DisposedITAT Delhi23 Jan 2023AY 2008-09

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5892/Del/2019, A.Y. 2008-09

Section 115JSection 143(3)Section 250

erroneously held that appellant’s 3. case is not covered by the case of My Home Power Ltd. [2014] 365 ITR 82. Book Profits u/s 115JB of the Income Tax Act, 1961 The Ld. CIT(A) and Ld. AO have grossly erred while 4. calculating Book Profit ... excluding the amount of receipt from transfer of CERs of Rs. 2,67,71,10,198/- from the book profit. 2 5892.Del.2019 M/s. SRF Limited The above grounds are without prejudice to each other. • The Appellant craves leave to alter, amend or withdraw • all or any of the grounds