Appellate Tribunal remits book profit computation issue under Section 115JB for reconsideration, emphasizing revised computations.

The Appellate Tribunal remitted the issue of book profit computation under Section 115JB of the Income Tax Act back to the Assessing Officer for reconsideration, allowing the appeal for statistical purposes. The Tribunal emphasized the significance of considering revised computations submitted during assessment proceedings and held that the rejection based solely on not being filed with the original return was contrary to precedent. The Tribunal did not provide a detailed analysis of the interest computation issue, focusing primarily on the book profit computation issue.

---

---

Issues involved:
1. Book profit computation under Section 115JB of the Act
2. Interest under Section 234C of the Act

Book profit computation under Section 115JB of the Act:
The appeal pertains to the assessment year 2012-13 and challenges the order of the Commissioner of Income Tax (Appeals) regarding the computation of book profits under Section 115JB of the Income Tax Act. The appellant submitted a revised computation of book profits during the assessment proceedings, which the Assessing Officer did not consider in the assessment order. The appellant argued that the revised computation was filed before the assessment order was passed. However, the Commissioner rejected the contention, stating that the Assessing Officer had considered the revised computation but rejected it as it was not claimed in the original return. The Commissioner held that the appellant falsely claimed that the revised computation was not considered. The Appellate Tribunal noted that the revised computation was rejected solely on the ground of not being filed with the original return, contrary to the Supreme Court's decision in Goetze (India) Ltd. v. CIT [2006] 284 ITR 323 (SC). The Tribunal remitted the issue back to the Assessing Officer for reconsideration on its merits, allowing the appeal for statistical purposes.

Interest under Section 234C of the Act:
The appellant also contested the Commissioner's failure to direct the Assessing Officer to compute interest under Section 234C of the Income Tax Act correctly. However, the Tribunal's judgment primarily focused on the book profit computation issue, remitting it back to the Assessing Officer for reconsideration. The Tribunal did not provide a detailed analysis of the interest computation issue in the summary provided.

In conclusion, the Appellate Tribunal's judgment addressed the appellant's challenge regarding the book profit computation under Section 115JB of the Act, remitting the issue back to the Assessing Officer for reconsideration. The Tribunal allowed the appeal for statistical purposes, emphasizing the importance of considering revised computations submitted during assessment proceedings.

---