TaxTMI 
TaxTMI 
2023 (8) TMI 677
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....1 (hereinafter the 'Act'), vide order of dated 13.12.2022. 2. The only issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the addition made by the AO of comprehensive income while computing book profit u/s. 115JB of the Act and adding an amount of Rs. 4,67,02,000/-. For this, Revenue has raised following ground No.2:- 2. The Ld. CIT(A) erred in deleting the addition made towards other comprehensive income amounting to Rs. 4,67,02,000/-, with the book profit without appreciating the fact that the starting point of income for the purpose of book profit is the profit before comprehensive income and therefore the book profit needs to be increased by the amount credited to other comprehensive income, as per the prov....
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....- P & L account and hence, the variance was Rs. 4,63,95,275. The assessee moved a rectification application with the CPC, Bangalore dated 26.06.2020 and the CPC, Bangalore rejected the rectification and passed order u/s. 154 of the Act on 15.08.2020 retaining the addition made by CPC u/s. 143(1) of the Act being comprehensive income of Rs. 4,67,02,000/-. Aggrieved, assessee preferred appeal before CIT(A). The CIT(A) after considering the submissions of the assessee and Explanation 1 to section 115JB(2) of the Act and also CBDT Circular No.24/2017 dated 25.07.2017 noted that as per proviso, the book profit of the previous year in which the asset or investment referred to in the first proviso is retired, disposed, realised or otherwise trans....
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....3/23/2015-TPL and subsequent issue of FAQ titled clarifications on computation of book profit for the purpose of levy of Minimum Alternate Tax (MAT) u/s. 115JB of the Act for Ind AS compliant companies. Wherein revaluation surplus of assets is to be computed in accordance with Indian Accounting Standards 16 and Indian Accounting Standards 38 and gains or loss in equity instruments designated at fair value through other comprehensive income in accordance with the Indian Accounting Standards 109 but this will not be included while computing book profit u/s. 115JB of the Act because proviso clearly bar from applying clause 'a' or 'b' in regard to comprehensive income. The relevant proviso provides as under:- "Provided that nothing contained ....