2015 (10) TMI 1621

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....f Rs. 1,13,13,831/- being provision for bad and doubtful debt in computation of book profit u/s 115JB of the I.T. Act, 1961. 3. At the time of hearing before us, it is submitted by the ld. Counsel for the assessee that under Rule 27 of the ITAT Rules, the respondent is permitted to support the order of the CIT(A) on any ground which is decided against him. He stated that before the CIT(A) the assessee has challenged the validity of reopening of assessment. The CIT(A) discussed the assessee's contention; however, ultimately did not agree with assessee's contention and decided the appeal of the assessee on merit, deleting the addition made by the Assessing Officer. Since the entire addition made by the Assessing Officer was deleted by the CI....

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.... furnished by the Assessing Officer, paragraph 1 reads as under:- "The return of income for the A.Y. 2003-04 filed by the assessee with ITO, Ward-5(1) Ahmedabad on 25-11-2003 declaring NIL. The case was reopened u/s 147 of the I.T. Act on the basis of audit objection raised by the revenue audit after obtaining the approval of the Commissioner of Income Tax. There after the case was transferred to the DDIT(E) Ahmedabad. The assessee trust is a limited company incorporated in October 1995 and converted into a company under section 25 of the Companies Act 1956 w.e.f. 25.12.2005." 6. Thus, the Assessing Officer has clearly mentioned that the case was reopened u/s 147 of the Income-tax Act on the basis of audit objection raised by the Revenue ....