Capital Reserve Excluded from MAT Calculation; Only Revaluation Reserve Affects Profit u/s 115JB.

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....MAT computation - Valuation of assets on amalgamation - determining book profit - Since, the capital reserve is out of purview of Section 115JB, and the “Revaluation Reserve” only is considered for upward adjustment of the profit as per the Act, the AO tried to being the capital reserve to the fold of Clause (j) [which rightly deals with revaluation reserve]. Such an action of the AO cannot be sustained. - AT....