IN THE INCOME TAX APPELLATE TRIBUNAL
" A " BENCH, CHENNAI
BEFORE Dr. O.K. NARAYANAN, VICE PRESIDENT &
SHRI S.S. GODARA, JUDICIAL MEMBER
I.T.A. Nos.1102 & 1103/Mds/2014
( / Assessment Years : 1999-2000 & 2000- 2001)
The Deputy Commissioner of M/s. Citi Financial Retail Services
Income Tax, Vs India Limited,
Company Circle I(3) 117, Radhakrishnan Salai,
Chennai 600 034. Mylapore,
Chennai 600 004.
( /Appellant) ( /Respondent)
/ Appellant by : Shri. Guru Bhashyam, IRS, JCIT.
/ Respondent by : Shri. V.S. Jayakumar, Advocate
/Date of hearing : 02.07.2014
/Date of Pronouncement : 02.07.2014
/ O R D E R
PER S.S. GODARA, JUDICIAL MEMBER
These Revenue's appeals for assessment years 1999-2000 and
2000 -2001, emanate from a common order dated 24.01.2014 passed
:- 2 -: ITA Nos.1102 & 1103/Mds/2014.
by the Commissioner of Income Tax (Appeals)-II, Chennai in ITA Nos.
380 & 381/13-14 respectively, in proceedings under section 143(3)
r.w.s 147 of the Income Tax Act 1961 [in short the "Act"] deleting
additions of `.97,19,760/- and `.1,69,31,685/- towards lease
equalization charges for the purposes of computing book profits u/s.
115JA of the Act.
Since the issue involved in both cases is identical, we take
up ITA No.1102/Mds/2014 as the `lead' case.
2 The assessee is a private limited company. It is engaged in the
business of leasing, hire purchase and finance of vehicles. On
16.12.1999, the assessee had filed its `return' admitting income of
`.90,22,970/- under `normal' computation and `.3,00,76,566/- under
'MAT' provisions u/s 115JA of the Act. The same was `summarily'
3. In scrutiny, the Assessing Officer noticed lease equalization
charges of `.97,19,760/- added back to the assessee's profits in
normal computation only and not for MAT's computation. He was of
the view that these charges had arisen in books from collection of
lease money more or less than the statutory depreciation allowable on
:- 3 -: ITA Nos.1102 & 1103/Mds/2014.