2021 (3) TMI 253

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....ng order in a mechanical manner without dealing with the various facts, submissions and case laws relied upon by the appellants. 2. The Ld. CIT(A) erred in law by erroneously observing that neither in the assessment proceedings nor in the appellant proceedings had the appellant submitted any working evidences to demonstrate that the said amount of Rs. 43,30,736/- has been determined on the basis of actuarial valuation, while both the hard copy and the soft copy of the said working was submitted to him by the appellant during the appellant proceedings. 3. The Ld. CIT(A) has erred in confirming the addition of amount of Rs. 43,30,736/- to book prof it of the appellant company, being provisions for gratuity by not appreciatin....

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....e company as per the provisions of Sec. 115JB of the Act. Therefore, the A.O. is of the opinion that, the assessee has failed to make the payment before the due date u/s 139(1) of the Act and hence made an addition of Rs. 43,30,736/- and calculated the minimum alternate tax (MAT) and passed the order u/s 143(3) of the Act on 30.03.2018. 3. Aggrieved by the order, the assessee has filed an appeal with the CIT(A), whereas the CIT(A) considered the grounds of appeal, findings of the A.O and the assesses submission referred at para 5.1 of the order. Finally, the Ld.CIT(A) concluded that the assessee has suo-moto made an addition while calculating the total income under the normal provisions of the Act. Further, it shows that the liability wa....