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766 results for “depreciation”+ Section 115clear

Sorted by relevance

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Key Topics

Section 143(3)61Addition to Income58Section 14A51Disallowance51Section 115J47Section 145A40Deduction35Depreciation22Section 11517Section 263

EVEREST INDUSTRIES LTD,NOIDA vs. DY CIT CIRLCE-1, THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 7793/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Jan 2023AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

DCIT, CIRCLE-1 ,, THANE vs. EVEREST INDUSTRIES LTD., MUMBAI

Showing 1–20 of 766 · Page 1 of 39

...
17
Section 14716
Section 153A16

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 1423/MUM/2020[2008-09]Status: DisposedITAT Mumbai31 Jan 2023AY 2008-09

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

DCIT CIRCLE-1 , THANE vs. M/S EVEREST INDUSTRIES LTD. , DELHI

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 653/MUM/2020[2013-14]Status: DisposedITAT Mumbai31 Jan 2023AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

EVEREST INDUSTRIES LTD.,NOIDA vs. DY CIT CIRCLE- 1, THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 715/MUM/2020[2008-09]Status: DisposedITAT Mumbai31 Jan 2023AY 2008-09

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

EVEREST INDUSTRIES LTD, NOIDA vs. DY CIT CIRLCE-1 , THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 7794/MUM/2019[2013-14]Status: DisposedITAT Mumbai31 Jan 2023AY 2013-14

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

DCIT CIRCLE-1 , THANE vs. M/S EVEREST INDUSTRIES LTD. , DELHI

In the result, the In the result, the assessee and Revenue are are educated as under:

ITA 654/MUM/2020[2012-13]Status: DisposedITAT Mumbai31 Jan 2023AY 2012-13

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

For Appellant: Mr. Yogesh Thar/
Section 115J

depreciation in the an assessee on account of appreciation or depreciation in the an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into value of foreign currency held by it, on conversion into anothercurrecny currecny, such profit or loss would

BANK OF INDIA,MUMBAI vs. ASST. CIT-2(1)(1), MUMBAI

In the result, the appeal of the Assessing Officer is partly allowed in the terms indicated above

ITA 1767/MUM/2019[2015-16]Status: DisposedITAT Mumbai11 Dec 2020AY 2015-16
Section 115Section 11JSection 143(3)Section 90Section 90(3)

depreciation, shall be the same as have been adopted for the purpose of preparing such accounts including (statement of profit and loss) and laid before the company at its annual general meeting in accordance with the provisions of (section 129) of the (Companies Act, 2013(18 of 2013)):" 15. The memorandum explaining the provisions made in the Finance Bill

ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

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

ITA 2108/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT
Section 32Section 35D

depreciation of ₹ 27,163,000 on goodwill arising on amalgamation. iv. Further on the difference of income of 2 companies, the learned CIT – A also asked that there is a bad debts written off out of the provision for doubtful debts, inadvertently not claimed in the original return of income filed but same was claimed in the revised return

PFIZER LTD,MUMBAI vs. DCIT - 14(2) (2), MUMBAI

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

ITA 2132/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT
Section 32Section 35D

depreciation of ₹ 27,163,000 on goodwill arising on amalgamation. iv. Further on the difference of income of 2 companies, the learned CIT – A also asked that there is a bad debts written off out of the provision for doubtful debts, inadvertently not claimed in the original return of income filed but same was claimed in the revised return

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ASSTT. CIT-CC-3(4), MUMBAI

In the result, appeal by the Revenue is dismissed

ITA 579/MUM/2021[2016-17]Status: DisposedITAT Mumbai14 Oct 2022AY 2016-17

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

For Appellant: Shri Nimesh Vora a/wFor Respondent: Shri Chetan M. Kacha, Sr. AR
Section 115JSection 143Section 144C(3)Section 14ASection 250Section 250(6)Section 32Section 92CSection 92C(3)

section 115 JB of the Act. As a result, ground No. 3 raised in assessee’s appeal is allowed. 12. The issue arising in ground No. 4, raised in assessee’s appeal, is pertaining to disallowance of depreciation

ACIT -3(4) , MUMBAI vs. RELIANCE INDUSTRIES LTD, MUMBAI

In the result, appeal by the Revenue is dismissed

ITA 1438/MUM/2021[2016-17]Status: DisposedITAT Mumbai14 Oct 2022AY 2016-17

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

For Appellant: Shri Nimesh Vora a/wFor Respondent: Shri Chetan M. Kacha, Sr. AR
Section 115JSection 143Section 144C(3)Section 14ASection 250Section 250(6)Section 32Section 92CSection 92C(3)

section 115 JB of the Act. As a result, ground No. 3 raised in assessee’s appeal is allowed. 12. The issue arising in ground No. 4, raised in assessee’s appeal, is pertaining to disallowance of depreciation

SHETH CREATORS PVT LTD.,MUMBAI vs. DY. CIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, the appeals of the assessee and appeal of the In the result, the appeals of the assessee and appeal of the revenue are allowed for statistical purposes

ITA 2620/MUM/2019[2015-16]Status: DisposedITAT Mumbai12 Aug 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), Upper Basement, Site Office, 19Th Floor, Air India Building, Vasant Oasis, Cts No. 345A/1 To Vs. Nariman Point, 3, 345A 5, Makwana Road, Mumbai-400021. Andheri East, Mumbai-400059. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2014-15 Dy. Cit, Central Circle-4(2), M/S Sheth Creators Private Limited, Room No. 1918, 19Th Floor, 1203 & 1204 Hallmark Business Air India Building, Vs. Plaza, 12Th Floor, Sant Dyaneshwar Nariman Point, Marg, Kala-Nagar, Bandra (East), Mumbai-400021. Mumbai-400051. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2015-16 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), 101-A & 1202, 1St & 12Th Floor, 18Th Floor, Air India Building, Hallamark Business Plaza, Near Vs. Nariman Point, Gurunanak Hospital, Sant Mumbai-400021. Dyaneshwar Marg, Kalanagar

section 115 JB of the Act at ₹52,25,837/ 837/-. Since the tax on the book profit was less . Since the tax on the book profit was less than the normal assessed income normal assessed income, therefore, tax was computed on tax was computed on the assessed income under regular provisions. the assessed income under regular provisions

SHETH CREATORS P. LTD.,MUMBAI vs. DY CIT CENTRAL CIRCLE-4(2), MUMBAI

In the result, the appeals of the assessee and appeal of the In the result, the appeals of the assessee and appeal of the revenue are allowed for statistical purposes

ITA 1858/MUM/2020[2014-15]Status: DisposedITAT Mumbai12 Aug 2022AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), Upper Basement, Site Office, 19Th Floor, Air India Building, Vasant Oasis, Cts No. 345A/1 To Vs. Nariman Point, 3, 345A 5, Makwana Road, Mumbai-400021. Andheri East, Mumbai-400059. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2014-15 Dy. Cit, Central Circle-4(2), M/S Sheth Creators Private Limited, Room No. 1918, 19Th Floor, 1203 & 1204 Hallmark Business Air India Building, Vs. Plaza, 12Th Floor, Sant Dyaneshwar Nariman Point, Marg, Kala-Nagar, Bandra (East), Mumbai-400021. Mumbai-400051. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2015-16 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), 101-A & 1202, 1St & 12Th Floor, 18Th Floor, Air India Building, Hallamark Business Plaza, Near Vs. Nariman Point, Gurunanak Hospital, Sant Mumbai-400021. Dyaneshwar Marg, Kalanagar

section 115 JB of the Act at ₹52,25,837/ 837/-. Since the tax on the book profit was less . Since the tax on the book profit was less than the normal assessed income normal assessed income, therefore, tax was computed on tax was computed on the assessed income under regular provisions. the assessed income under regular provisions

SHETH CREATORS PVT LTD.,MUMBAI vs. DY. CIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, the appeals of the assessee and appeal of the In the result, the appeals of the assessee and appeal of the revenue are allowed for statistical purposes

ITA 3696/MUM/2019[2016-17]Status: DisposedITAT Mumbai12 Aug 2022AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), Upper Basement, Site Office, 19Th Floor, Air India Building, Vasant Oasis, Cts No. 345A/1 To Vs. Nariman Point, 3, 345A 5, Makwana Road, Mumbai-400021. Andheri East, Mumbai-400059. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2014-15 Dy. Cit, Central Circle-4(2), M/S Sheth Creators Private Limited, Room No. 1918, 19Th Floor, 1203 & 1204 Hallmark Business Air India Building, Vs. Plaza, 12Th Floor, Sant Dyaneshwar Nariman Point, Marg, Kala-Nagar, Bandra (East), Mumbai-400021. Mumbai-400051. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2015-16 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), 101-A & 1202, 1St & 12Th Floor, 18Th Floor, Air India Building, Hallamark Business Plaza, Near Vs. Nariman Point, Gurunanak Hospital, Sant Mumbai-400021. Dyaneshwar Marg, Kalanagar

section 115 JB of the Act at ₹52,25,837/ 837/-. Since the tax on the book profit was less . Since the tax on the book profit was less than the normal assessed income normal assessed income, therefore, tax was computed on tax was computed on the assessed income under regular provisions. the assessed income under regular provisions

DY CIT CENTRAL CIRCLE-4(2),, MUMBAI vs. M/S SHETH CREATORS P. LTD., MUMBAI

In the result, the appeals of the assessee and appeal of the In the result, the appeals of the assessee and appeal of the revenue are allowed for statistical purposes

ITA 2012/MUM/2020[2014-15]Status: DisposedITAT Mumbai12 Aug 2022AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), Upper Basement, Site Office, 19Th Floor, Air India Building, Vasant Oasis, Cts No. 345A/1 To Vs. Nariman Point, 3, 345A 5, Makwana Road, Mumbai-400021. Andheri East, Mumbai-400059. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2014-15 Dy. Cit, Central Circle-4(2), M/S Sheth Creators Private Limited, Room No. 1918, 19Th Floor, 1203 & 1204 Hallmark Business Air India Building, Vs. Plaza, 12Th Floor, Sant Dyaneshwar Nariman Point, Marg, Kala-Nagar, Bandra (East), Mumbai-400021. Mumbai-400051. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2015-16 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), 101-A & 1202, 1St & 12Th Floor, 18Th Floor, Air India Building, Hallamark Business Plaza, Near Vs. Nariman Point, Gurunanak Hospital, Sant Mumbai-400021. Dyaneshwar Marg, Kalanagar

section 115 JB of the Act at ₹52,25,837/ 837/-. Since the tax on the book profit was less . Since the tax on the book profit was less than the normal assessed income normal assessed income, therefore, tax was computed on tax was computed on the assessed income under regular provisions. the assessed income under regular provisions

SHETH CREATORS PVT. LTD.,MUMBAI vs. DY CIT CENT. CIR-4(2), MUMBAI

In the result, the appeals of the assessee and appeal of the In the result, the appeals of the assessee and appeal of the revenue are allowed for statistical purposes

ITA 1857/MUM/2020[2017-18]Status: DisposedITAT Mumbai12 Aug 2022AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), Upper Basement, Site Office, 19Th Floor, Air India Building, Vasant Oasis, Cts No. 345A/1 To Vs. Nariman Point, 3, 345A 5, Makwana Road, Mumbai-400021. Andheri East, Mumbai-400059. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2014-15 Dy. Cit, Central Circle-4(2), M/S Sheth Creators Private Limited, Room No. 1918, 19Th Floor, 1203 & 1204 Hallmark Business Air India Building, Vs. Plaza, 12Th Floor, Sant Dyaneshwar Nariman Point, Marg, Kala-Nagar, Bandra (East), Mumbai-400021. Mumbai-400051. Pan No. Aapcs 2976 M Appellant Respondent Assessment Year: 2015-16 Sheth Creators Private Limited, Dy. Cit, Central Circle-4(2), 101-A & 1202, 1St & 12Th Floor, 18Th Floor, Air India Building, Hallamark Business Plaza, Near Vs. Nariman Point, Gurunanak Hospital, Sant Mumbai-400021. Dyaneshwar Marg, Kalanagar

section 115 JB of the Act at ₹52,25,837/ 837/-. Since the tax on the book profit was less . Since the tax on the book profit was less than the normal assessed income normal assessed income, therefore, tax was computed on tax was computed on the assessed income under regular provisions. the assessed income under regular provisions

DCIT CIR. 2(1)(2), MUMBAI vs. M/S CENTRAL BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the

ITA 1279/MUM/2020[2016-17]Status: DisposedITAT Mumbai22 Aug 2025AY 2016-17
For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

depreciation and provision for\ndepreciation on transfer of securities. Disagreeing with the submissions of the\nassessee, the AO vide order dated 12/03/2020 passed under section 154 of the\nAct recomputed the book profit under section 115

CENTRAL BANK OF INDIA,MUMBAI vs. ACIT - 2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the

ITA 1078/MUM/2018[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16
For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

depreciation and provision for\ndepreciation on transfer of securities. Disagreeing with the submissions of the\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 30\nassessee, the AO vide order dated 12/03/2020 passed under section 154 of the\nAct recomputed the book profit under section 115

DCIT 2(1)(1), MUMBAI vs. CENTRAL BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the

ITA 1223/MUM/2018[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16
For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

depreciation and provision for\ndepreciation on transfer of securities. Disagreeing with the submissions of the\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 29\nassessee, the AO vide order dated 12/03/2020 passed under section 154 of the\nAct recomputed the book profit under section 115

JT. CIT (OSD) -2(1)(2), MUMBAI vs. CENTRAL BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the

ITA 3674/MUM/2018[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14
For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

depreciation and provision for\ndepreciation on transfer of securities. Disagreeing with the submissions of the\n\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 30\n\nassessee, the AO vide order dated 12/03/2020 passed under section 154 of the\nAct recomputed the book profit under section 115