Held that the Tribunal had recorded findings that in the assessment order the Assessing Officer had not given any reason for making upward adjustment while calculating the book profit for the purpose of minimum alternate tax and despite this fact the Commissioner had presumed that the Assessing Officer might have invoked the provisions of section 115JB(2)(c) by treating the loans and advances which were actually written off as doubtful, that the assessee had consistently submitted that the loss was real and such loss had been debited to the profit and loss account under the head provision for doubtful loans and advances, that from the perusal of audited account it was clear that it was written off in the account as irrecoverable though the nomenclature was used as provision and that the Department could not show any factual matrix which led them to take a view that such amount was not certain and was merely a provision. No question of law arose.(AY. 2004-05)