The assessee reduced the provision for card receivables written back in computing Book Profits for AY. 2012-13. However, the provision for card receivables was not added back in computing Book Profit for earlier years.

It was submitted that provision for diminution in value of asset was to be added to Book Profits vide Finance (No. 2) Act, 2009 with retrospective effect from A.Y. 2001-02. Further, the assessee had book loss in the earlier years and even if the provision for card receivables was added back in computing Book Profits, there would still be a loss and accordingly revised working for Book Profit were submitted.

The Tribunal after considering the revised workings of the Book Profits noted that the assessee would not be liable to Book Profits. Further, the Tribunal noted that similar claim of assessee for AY. 2011-12 was accepted by the Department. Thus, following the principle of consistency the claim of the assessee was to be accepted. (AY. 2012-13)