Karnataka State Industrial Infrastructure Development Corporation Ltd. v. DCIT (2020) 83 ITR 386 / 185 ITD 441/ ( 2021 ) 211 TTJ 362 (Bang.)(Trib.)

S. 115JB : Book profit-No addition will be made in respect of disallowance under section 14A, read with rule 8D-Benefit of clause (i) of Explanation 1 to section 115JB (2) will not be available to assessee if book profit was not increased by amount of provision made in year of making provision for whatever reason. [S. 14A, R.8D]

For purpose of computing book profit, no addition will be made in respect of disallowance under section 14A, read with rule 8D. If any provision was made by assessee after 1-4-1997 and same is withdrawn in present year, then book profit has to be reduced by amount of provisions written back but such reduction from book profit is not allowable if in year of creation of provision, it was not added back to book profit and, thus, benefit of clause (i) of Explanation 1 to section 115JB (2) will not be available to assessee if book profit was not increased by amount of provision made in year of making provision for whatever reason. (AY. 2011-12)