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Transfer-pricing adjustments cannot be added to book profits under section 115JB without accounting defect findings

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Full Text of the Document

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....ITAT held that the AO lacked jurisdiction to add back a transfer-pricing adjustment to book profits under section 115JB beyond the limited adjustments expressly permitted by the Explanation to that section; absent findings that the profit and loss account was not prepared in accordance with the Companies Act or that incorrect accounting policies, standards or depreciation methods were adopted, the AO cannot go behind the net profit shown in the accounts. The appeal was allowed: the AO is directed to exclude any transfer-pricing adjustment, if it survives, from the computation of book profits under section 115JB.....