“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

M/S Information Technology Park Limited, Bangalore vs. Income Tax Officer Ward-3(1)(4), Bangalore

ITA 1357/BANG/2018[2009-10]Status: DisposedITAT Bangalore24 Aug 2022AY 2009-10

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Rajesh Kumar Jha, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(2)Section 143(3)Section 2(22)

amount of income-tax claimed as refund, if any, 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

Hikal Ltd, Mumbai vs. DCIT Cir 3(1), Mumbai

In the result appeal of the assessee for A

ITA 5388/MUM/2012[2009-10]Status: DisposedITAT Mumbai23 Aug 2022AY 2009-10

Section 10ASection 10BSection 143(3)

assessee is allowed. 8. The ground No.11 raised by the assessee is challenging the disallowance made u/s.14A of the Act while computing book profits u/s.115JB of the Act. The facts relevant for adjudication of this ground is already detailed by us in ground No.9 above. We find that the Special

Hikal Ltd, Mumbai vs. DCIT Cir 3(1), Mumbai

In the result appeal of the assessee for A

ITA 5387/MUM/2012[2008-09]Status: DisposedITAT Mumbai23 Aug 2022AY 2008-09

Section 10ASection 10BSection 143(3)

DCIT (OSD) Cir 3(1), Mumbai vs. Hikal Ltd, Mumbai

In the result appeal of the assessee for A

ITA 5372/MUM/2012[2009-10]Status: DisposedITAT Mumbai23 Aug 2022AY 2009-10

Section 10ASection 10BSection 143(3)

Greaves Cotton Ltd., Mumbai vs. DCIT Cir 6(3), Mumbai

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

ITA 7742/MUM/2014[2010-11]Status: DisposedITAT Mumbai22 Aug 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.7742/मुं/2014 ("न.व. 2010-11) Greaves Cotton Ltd. 3Rd Floor, Motilal Oswal Tower, Junction Of Gokhale & Sayani Road, Prabhadevi, Mumbai 400 025. Pan: Aaacg-2062-M ...... अपीलाथ" /Appellant बनाम Vs. Dy. Commissioner Of Income Tax, Circle 6(3), Aaykar Bhavan, M.K.Road, ..... ""तवाद"/Respondent Mumbai 400 020. अपीलाथ" "वारा/ Appellant By : Smt. Aarti Vissanji, Advocate ""तवाद" "वारा/Respondent By : Smt. Vranda U. Matkari, Sr.A.R सुनवाई क" "त"थ/ Date Of Hearing : 27/05/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 22/08/2022 आदेश/ Order

For Appellant: Smt. Aarti Vissanji, AdvocateFor Respondent: Smt. Vranda U. Matkari, Sr.A.R

Section 10(54)Section 115OSection 143(3)Section 14A

Ground C: Unutilized Cenvat Credit – Rs.9,32,524/- Ground D: Capital Receipt treated as Long Term Capital Gains – Rs.81,10,875/- Ground E : Book Profit – Provision for Expenses – Rs.2,06,71,770/- Ground F : Book Profit – Disallowance u/s. 14A r.w.r. 8D Ground G : Credit for Payment of Tax u/s. 115O ... thus, allowed for statistical purposes. 13. In ground ‘E’ of appeal, the assessee has assailed addition on account of Provision for Expenses while computing book profit under section 115JB of the Act. The ld.Counsel for the assessee submitted that this ground is covered by order of Tribunal in assessee

Creative Ashtech Powr Projects P. Ltd., Mumbai vs. Asst. CIT-14(1)(2), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 946/MUM/2021[2012-13]Status: DisposedITAT Mumbai18 Aug 2022AY 2012-13

Bench: Shri Baskaran B.R & Shri Pavan Kumar Gadalecreative Ashtech Power Vs. Acit – 14(1)(2) Projects Pvt Ltd., Aayakar Bhavan, 7Th Floor, Raheja Point I, M.K.Road, Opp Vakola Market, Mumbai – 400020. Nehru Road,Santacruz (E) Mumbai- 400055. Pan/Gir No. : Aadcd1054F Appellant .. Respondent Appellant By : Mr. Amit Khatiwala.Ar Respondent By : Mr. Ganesh Bare. Cit Dr Date Of Hearing 22.08.2022 Date Of Pronouncement 24.08.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Cit(A)- National Faceless Appeal Centre (Nfac), Delhi, Passed U/S 154 & 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Mr. Amit Khatiwala.ARFor Respondent: Mr. Ganesh Bare. CIT DR

Section 115JSection 143(3)Section 14ASection 154

merits of the case as filed vide submissions dated 25.01.2021. Without prejudice to the above, our grounds on merit are as under: COMPUTATION OF BOOK PROFIT U/S. 115JB OF THE ACT Creative Ashtech Power Projects, Mumbai. B. ADDITION OF DISALLOWANCE UNDER SECTION 14A OF THE ACT WHILE COMPUTING BOOK PROFIT ... account of expenses incurred in relation to exempt income based on the computation as provided in section 14A and Rule 8D while computing book profit u/s. 115JB of the Act. Your Appellant submits that the provisions of section 14A and Rule 8D are applicable only in respect of computation under

Jt. Comm of Income Tax (OSD), CC - 7(2), Mumbai vs. M/S. Rajamundry Expressway Pvt. Ltd, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1587/MUM/2021[2014-15]Status: DisposedITAT Mumbai17 Aug 2022AY 2014-15

Bench: Us :-

Section 143(3)Section 32(1)(ii)Section 37(1)Section 40A(2)Section 801ASection 80I

circumstances of the case and in the law, the Ld. CIT(A) erred in deleting the disallowance of provisions for periodic maintenance charges from book profit without considering the fact that decision of the Mumbai Tribunal in the case of Anchor Electricals (P) Ltd. vs DCIT (2017) is not applicable ... circumstances of the case, Ld. CIT(A) erred in deleting the disallowance made on account of provision for periodic maintenance charges while computing the book profits u/s 115JB of the Income Tax act 1961, without considering the facts that the expenditure has neither crystallized nor incurred during the tear under

Assistant Commissioner of Income Tax Circle-2(3)(1), Mumbai vs. Tata Sons Limited, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 4323/MUM/2017[2011-12]Status: DisposedITAT Mumbai16 Aug 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Ms. Aarti Vissanji a/wFor Respondent: Shri Tejinder Pal Singh

Section 143(2)Section 143(3)Section 250Section 92C

Pension amount: The CIT(A) erred in disallowing net provision for pension of Rs.21.94 crore, provided on an actuarial basis. 12) Additional Ground: Adjusted Book Profit under section 115JB: The assessing officer erred in not including the income as computed under the head Capital Gains in accordance with ... result, ground no. 11 raised in assessee’s appeal is allowed. 35. Ground No. 12, raised in assessee’s appeal, pertaining to computation of book profit under section 115JB of the Act was not pressed during the course of hearing. Accordingly, the said ground is dismissed as not pressed

Tata Sons Ltd., Mumbai vs. ACIT, Cir 2(3)(1), Mumbai

In the result, appeal by the Revenue is dismissed

ITA 4221/MUM/2017[2011-12]Status: DisposedITAT Mumbai16 Aug 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Ms. Aarti Vissanji a/wFor Respondent: Shri Tejinder Pal Singh

Section 143(2)Section 143(3)Section 250Section 92C

ACIT 2(2)(1), Mumbai vs. Mahima Stocks Pvt. Ltd., Mumbai

In the result, the orders passed by the Income Tax Appellate Tribunal to the extent it is against the assessee are hereby quashed

ITA 2486/MUM/2021[2015-16]Status: DisposedITAT Mumbai11 Aug 2022AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhacit – 2(2)(1) Vs. M/S Mahima Stocks Room No. 545, 5Th Floor Pvt Ltd Aayakarbhavan, 1,Gaureshapartments, M.K.Road, Old Police Line, Mumbai – 400020. Andheri (E) Mumbai – 400069. Pan/Gir No. : Aaecm2983K Appellant .. Respondent Appellant By : Smt.Mahita Nair.Dr Respondent By : Shri.Vimal Punmiya.Ar Date Of Hearing 10.08.2022 Date Of Pronouncement 24.08.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Cit(A)- National Faceless Appeal Centre (Nfac), Delhi Passed U/S143(3) & U/Sec250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Smt.Mahita Nair.DRFor Respondent: Shri.Vimal Punmiya.AR

Section 115JSection 143(2)Section 143(3)Section 48

income for the A.Y 2015-16 with a total income of Rs.7,70,42,550/- under the normal provisions of the Act and the book profits computed u/s 115JB of the Act at Rs. 12,58,87,769/-.The assessee was called to furnish the details/ explanations for filing ... revised return of income and reduction in computing the Book Profits. The assessee has filed a letter dated 27.09.2017 and the A.O has referred to the facts/details at page 3 of the assessment order. 3. Whereas the A.O was not satisfied with the submissions and is of the opinion that

The Great Eastern Shipping Co., Mumbai vs. Addl.C.I.T. RG.5(3), Mumbai

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

ITA 197/MUM/2013[2008-09]Status: DisposedITAT Mumbai11 Aug 2022AY 2008-09

For Appellant: Shri Percy j. Pardiwalla, Sr. Advocate with S/Sh. Jitendra Jain& Rashid PoonawalFor Respondent: Dr.Yogesh Kamat , CIT and Shri Sambit Mishra

Section 115JSection 143(3)Section 14ASection 14A(2)

r.w.r 8D. (ii) Ground No.2: Challenge to recording of satisfaction u/s. 14A(2). (iii) Ground No.3: Inclusion of disallowance u/s. 14A while computing book profits u/s. 115JBof the Act. 3 3. Shri Percy j. Pardiwalla narrating the facts of case submitted that the assessee is engaged in the business ... other business (Business other than of the business of qualifying ships) is at page 34 of the Paper Book. A perusal of computation of book profit would show that interest and finance charges Rs.9.21 crores was allocated to non- tonnage activities(Business other than of the business of qualifying ships

DCIT (It) 2(1)(1), Mumbai vs. Credit Suisse Ag, Mumbai

In the result, appeal of the Revenue is dismissed and Cross

ITA 14/MUM/2019[2015-16]Status: DisposedITAT Mumbai04 Aug 2022AY 2015-16

Section 143(3)Section 5(2)Section 9(1)(vii)

challenging the action of the ld. CIT(A) wherein the ld. CIT(A) had directed the ld. AO to delete five items while calculating book profits u/s.115JB of the Act. The interconnected issue involved therein is whether the provisions of Section 115 JB of the Act per se would ... account is to be prepared in terms of Part-II and Part-III of Schedule-VI of the Companies Act, 1956 for determination of book profits u/s.115JB of the Act. In respect of a foreign company, the profit and loss account need not be prepared in terms of Part

Dy.C.I;.T.Central Cir6 (3), Mumbai vs. M/S. Reynold Shirting Ltd, Mumbai

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

ITA 2388/MUM/2021[2017-18]Status: DisposedITAT Mumbai03 Aug 2022AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhdcit, Cc – 6(3) Vs. Reynold Shirting Ltd Room No. 1926, 19Th 402, 4Th Floor, Kamla Floor, Air India Bldg, Hub Ns Road No.1 Nariman Point, Juhu Scheme, Vile Mumbai-400021. Parle (W), Mumbai -400049. Pan/Gir No. : Aaccr7055H Appellant .. Respondent Appellant By : Ms.Mahita Nair.Dr Respondent By : Ms.Mitalli Gopani.Ar Date Of Hearing 03.08.2022 Date Of Pronouncement 08.08.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals) – 54, Mumbai Passed U/S 143(3) & 250. The Revenue Has Raised The Following Revised Grounds Of Appeal:

For Appellant: Ms.Mahita Nair.DRFor Respondent: Ms.Mitalli Gopani.AR

Section 115JSection 143(2)Section 143(3)Section 14A

extent of exempt income earned Rs. 57,500/- and also the A.O. was directed to exclude disallowance u/s 14A of the Act while computing book profits u/s 115JB of the Act and partly allowed the assessee appeal. Aggrieved by the order of the CIT(A), the revenue has filed

ACIT CC 3(3), Mumbai vs. M/S. Welspun Steel Ltd, Mumbai

Accordingly, Ground No. 2 raised by the Revenue is dismissed

ITA 2137/MUM/2021[2015-16]Status: DisposedITAT Mumbai03 Aug 2022AY 2015-16

For Appellant: Ms. Ira BahlFor Respondent: Shri Nikhil Chaudhary

Section 1Section 143(3)Section 14ASection 153A

justified in directing the Assessing Officer to delete the disallowance made under section 14A r.w. Rule 8D to the Book profit relying on decision of Hon‟ble ITAT in the assessee‟s own case for the A.Y. 2013-14 & 2014-15 wherein the Hon‟ble Tribunal followed special Bench decision ... appeal is directed against the order of CIT(A) whereby the Assessing Officer has been directed to not include in the book profits the amount of disallowance under section 14A of the Act computed as per the provisions of Rule 8D of the Rules for the purpose of computing book

Welspun Steel Ltd. (Successor in Interest to Welspun Energy Pvt. Ltd.), Mumbai vs. ITO 8(3)(2), Mumbai

ITA 2786/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Aug 2022AY 2014-15

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Hoshang B. Irani

Section 1Section 115JSection 143(3)Section 14A

disallowance of INR 4,98,43,035/- under the normal provisions of the Act. The Assessing Officer also added the aforesaid amount while computing book profits under the provisions of Section 115JB of the Act. 6. Being aggrieved, the Assessee carried this issue in appeal before ... Section 14A of the Act to the amount of exempt income of INR 52,85,697/- earned by the Assessee. As regards, computation of books profits under Section 115JB of the Act, the CIT(A) granted relief to the Assessee following the decision of Special Bench of the Tribunal

ACIT, Central Circle1(3), Mumbai vs. M/S. Peninsula Land Limited, Mumbai

In the result the appeal filed by the revenue is dismissed

ITA 5632/MUM/2019[2009-10]Status: DisposedITAT Mumbai29 Jul 2022AY 2009-10

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahaman, Accountat Member Ita No. 5632 & 5633/Mum/2019 (A.Y: 2009-10 & 2010-11) Acit, Cc – 1(3) Vs. M/S Peninsula Land 905, 9Th Floor, Pratistha Ltd., Bhavan, Old Cgo Bldg, No. 2, Peninsula (Annexe), M.K .Road, Spenta, Mathuradas Mumbai – 400020. Mill Compound, Senapati Bapat Marg, Parel, Mumbai- 400013. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaact5173A Appellant .. Respondent Appellant By : Shri. Aditya Rai. Dr Respondent By : Shri. Vijay Mehta.Ar Date Of Hearing 24.06.2022 Date Of Pronouncement 28.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: These Are The Two Appeals Filed The By The Revenue Against The Common Order Of The Commissioner Of Income Tax (Appeals)-47, Mumbai Passed U/S 153A R.W.S 143(3) & 250 Of The Act.

For Appellant: Shri. Aditya Rai. DRFor Respondent: Shri. Vijay Mehta.AR

Section 115JSection 132Section 143(2)Section 143(3)Section 153A

peninsula Land Ltd., Mumbai. income for the A.Y 2009-10 on 29.010.2009 disclosing a total income of Rs.1,18,55,09,815/- and Book profit of Rs.1,77,23,33,136/- u/s 115JB of the Act. Subsequently, the assessee has filed the revised return of income on 01.03.2011 disclosing ... total income of Rs.1,49,77,61,310/- under the normal provisions of the Act and Book profits of Rs. 1,80,62,25,822/- u/s 115JB of the Act. Subsequently the case was selected for scrutiny and the assessment was completed u/s 143(3) of the Act determining

Addl CIT RG 10(2), Mumbai vs. Geometric Softwar Solutions Co. Ltd, Mumbai

In the result, ground no

ITA 6219/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Jul 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm M/S Geometric Software The Acit Solutions Company Ltd. Ward 10(2), [ Now Merged With Hcl Room No.432, 4Th Floor, Technologies Limited ] Vs. Aayakar Bhavan, M.K. Marg, 806, Sidharth, 96 Nehru Mumbai-400 020 Place, New Delhi 19 (Respondent) (Appellant) Pan No. Aabcg 0066 A Co No. 157/Mum/2011 (Arising In Ita No.6219/Mum/2010 For A.Y. 2005–06) M/S Geometric Software Solutions Company Ltd. The Acit (Now Gemetric Ltd.) [ Now Ward 10(2), Room No.432, 4Th Floor, Merged With Hcl Vs. Technologies Limited] Aayakar Bhavan, M.K. Marg, Mumbai-400 020 806, Sidharth, 96 Nehru Place, New Delhi 19 (Respondent) (Cross Objector) Assessee By : Shri Porus F. Kaka & Shri Manish Kanth, Ars‟ Revenue By : Shri Sumit Kumar, Dr Date Of Hearing: 21.07.2022 Date Of Pronouncement : 29.07.2022

For Appellant: Shri Porus F. Kaka &For Respondent: Shri Sumit Kumar, DR

Section 10ASection 14A

earning Geometric software solutions co. ltd; A.Y. 05–06 of exempt dividend income and thereafter reducing only the net dividend income, while computing book profits u/s. 115JB of the Act. 10) The learned Commissioner of Income Tax (Appeals) erred in confirming the action of the Assessing Officer in relying ... provisions of Section 14A of the Act and Rule 8D of the Rules while computing the amount liable for being added back to the book profits to be computed under section 115JB of the Act.” 04. The learned assessing officer has raised following grounds of appeal:- 1. On the facts

Geometric Software Solutins Co. Ltd ( Now Gemetric Ltd), Mumbai vs. Addl CIT RG 10(2), Mumbai

In the result, ground no

ITA 5975/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Jul 2022AY 2005-06

For Appellant: Shri Porus F. Kaka &For Respondent: Shri Sumit Kumar, DR

Section 10ASection 14A

DCIT- 12 (2)(2), Mumbai vs. Guruashish Construction Pvt. Ltd., Mumbai

ITA 2861/MUM/2018[2013-14]Status: DisposedITAT Mumbai26 Jul 2022AY 2013-14

For Appellant: NoneFor Respondent: Shri Hoshang B. Irani

Section 115JSection 133ASection 142ASection 143(2)Section 143(3)

Assessment Year 2013-14 on 28.09.2013 declaring total income of INR 1,49,741/- under normal provisions of the Act and declaring book profits of INR 1,89,031/- under Section 115JB of the Act. The case of the Assessee was selected for scrutiny and notice under Section

DCIT 8(2), Mumbai vs. Pantaloon Industries Ltd, Mumbai

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

ITA 5651/MUM/2014[2009-10]Status: DisposedITAT Mumbai25 Jul 2022AY 2009-10

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaledcit – 8(2) Vs. Pantaloon Industries Aayakar Bhavan Ltd, Ground Floor, M.K .Road Knowledge House, Off Mumbai – 400020. Jogeswari Vikroli Link Road, Shyam Nagar, Jogeswari (E) Mumbai – 400060. Pan/Gir No. : Aabcp9866D Appellant .. Respondent Pantaloon Industries Ltd Vs. Dcit – 8(2) Ground Floor, Knowledge Aayakar Bhavan House, Off Jogeswari M.K .Road, Vikroli Link Road, Shyam Mumbai – 400 020. Nagar, Jogeswari (E) Mumbai – 400 060. Pan/Gir No. : Aabcp9866D Appellant .. Respondent

Section 10(34)Section 143Section 143(1)Section 143(2)Section 143(3)Section 154

rectification of mistake apparent from record for not considering the disallowance u/sec14A r.w.r 8D2(iii) of the I T Rules in computing the Book Profits U/sec115JB of the Act. Whereas, the asssessee has filed a letter dated 21-03-2013 raising the objections on the claim. Finally ... passed the rectification order by determining the Book profits u/s 115JB of the Act including the disallowance u/s 14A of the Act which worked out to Rs9,98,01,440/- and passed the order u/s 154 of the Act dated 24.04.2013. 4. Aggrieved by the order