2019 (2) TMI 1372

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.....2004 which was revised on 31.03.2005. The assessment was completed on 31.11.2006 u/s 143(3) of the Act on total income of Rs. 11,28,40,516/-. The computation of MAT on account of book profit was filed as per which there was a tax payable u/s 115JB of the Act. 4. Later on the completed assessment was reopened by issue of notice u/s 148 of the Act. The reasons for reopening the assessment was that the assessee had made provision for operating expenses of Rs. 7.34 crores out of which only Rs. 4.85 crores was added back by the assessee in the computation of income. The balance of Rs. 2.49 crores remained to be added to the income. 5. The reassessment proceedings were completed by order dated 21.12.2011 framed u/s 143(3) r/w section 147 of th....

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....s 271 (1) (c) of the Act. In the light of the following circular of CBDT :- "Subject: Penalty u/s 271(1)(c) wherein additions/disallowances made under normal provisions of the Income Tax Act, 1901 hut tax levied under MAT provisions u/s 115 JB/1 15JC, for cases prior to AD 2016- 17-rcg.- Section 115JB of the Act is a special provision for levy of Minimum Alternate Tax on Companies, inserted by Finance Act 2000 with effect from I-4-2001. 2. Under clause (iii) of sub-section (1) o! 'section 27! of the Act. penalty for concealment of income or furnishing inaccurate particulars of income is determined based on the "amount of tax .sought to he evaded" which has been defined inter cilia, as the difference between the tax due on the in....