2022 (6) TMI 631

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....e u/s.115JB of the Act. 2. In this regard, the ld. Authorised Representative (ld. AR for short) of the assessee had submitted that the Revenue has wrongly decided the issue while computing the book profit off the assessee u/s.115JB and have taken into account the amount of interest while calculating the book profit. He has drawn our attention to Explanation 1 to section 115JB of the Act. He submitted that the amount of interest (the difference of the amount) which was reflected in section 26AS cannot be added to the book profit, as the same was not provided under the Explanation 1 to section 115JB. It was also the contention of the ld. AR that the Hon'ble Supreme Court in the case of Apollo Tyres v. CIT (255 ITR 273)(SC) has decided th....

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....f Hon'ble Supreme Court in Apollo Tyres will not be applicable. The addition made by the AO is accordingly, upheld. 4. We have heard the rival contention and perused the material available on record. Undoubtedly, during the assessment proceedings, the Assessing Officer had asked the assessee to reconcile the income appearing in Form 26AS. After that enquiry by the Assessing Officer, the assessee offered the income of Rs.30,82,223/- under the normal computation of income, which reads as under: 5.1 During the assessment proceedings, the assessee was asked to reconcile the income appearing in the Form 26AS. The assessee submitted the details vide letter dated 26.12.2016 regarding teh reason for the difference. The assessee offered the i....