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of ITAT allowed the assessee's appeal on multiple grounds. Regarding book profit computation under section 115JB, the Tribunal held that write-offs from court-approved capital reduction constitute transfer under section 2(47), following binding precedents from Gujarat HC and SC in Torrent and Apollo Tyres cases. The capital reduction was properly approved by Bombay HC and registered with ROC, resulting in share extinguishment and cancellation of investment rights. On procedural grounds, ITAT ruled CIT(A) improperly enhanced assessment by directing deemed dividend additions under sections 2(22)(d) and 115QA without issuing mandatory show-cause notice as required under section 251(2), relying on SC precedents in Chamaria and Mistry cases. For section 80IA deduction, ITAT allowed rental income from CFS operations as eligible business income, supported by CBDT circular and consistent treatment in previous assessment years for the same assessee.
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