Dear Sir,<\/p>\n
The assessee filed return of income declaring loss under both normal provisions and section 115JB of the Act.<\/p>\n
The AO made additions under normal provisions. However, due to availability of b\/f losses, the tax payable under normal provisions was Nil.<\/p>\n
The AO also made additions to book profit and determined a book profit on which MAT is payable. Accordingly demand ha been raised.<\/p>\n
The assessee filed appeal before CIT(A) for additions made under the normal provisions (Additions to book profits were not contested before the CIT(A)). The CIT(A) order was passed against the assessee.<\/p>\n
The assessee filed appeal before the ITAT and the same is pending before the ITAT as on 31.01.2020. The assessee has also filed additional grounds before the ITAT in respect of the additions made to the book profit. The appeal is pending as on date.<\/p>\n
The assessee wishes to file under VsV and c\/f reduced losses under the normal provisions. <\/p>\n
Queries:<\/p>\n
1. Whether the assessee can file under the VsV scheme for the additional grounds raised before ITAT which have not been raised before CIT(A).<\/p>\n
2. If yes, do the assessee need to file separate applications under VsV, one for normal provisions and other for book profit additions.<\/p>\n
Request your valuable views on above. <\/p>\n","protected":false},"excerpt":{"rendered":"
Dear Sir, The assessee filed return of income declaring loss under both normal provisions and section 115JB of the Act. The AO made additions under normal provisions. However, due to availability of b\/f losses, the tax payable under normal provisions was Nil. The AO also made additions to book profit and determined a book profit on which MAT is payable. Accordingly demand ha been raised. The assessee filed appeal before CIT(A) for additions made under the normal provisions (Additions to book profits were not contested before the CIT(A)). The CIT(A) order was passed against the assessee. The assessee filed appeal before the ITAT and the same is pending before the ITAT as on 31.01.2020. The assessee has also filed additional grounds before the ITAT in respect of the additions made to the book profit. The appeal is pending as on date. The assessee wishes to file under VsV and c\/f reduced losses under the normal provisions. Queries: 1. Whether the assessee can file under the VsV scheme for the additional grounds raised before ITAT which have not been raised before CIT(A). 2. If yes, do the assessee need to file separate applications under VsV, one for normal provisions and other for book profit additions. Request your valuable views on above.<\/p>\n