आदेश/ORDER

PER SHRI MADHUSUDAN SAWDIA, A.M:

These cross appeals filed by M/s. HSBC Electronic Data Processing India Pvt. Ltd. (“assessee”) and Revenue, against the order dated 30/05/2017 of the learned Commissioner of Income Tax (Appeals)-9, Hyderabad (“Ld. CIT(A)”) relating to A.Y.2010- 11. For the sake of convenience, we decide these appeals by way of this common order.

2. First, we take up appeal of the assessee in ITA No.1613/Hyd/2017. The revised / modified grounds of appeal raised by the assessee read as under:

“Based on the facts and circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals) -

9 [’CIT(A)’/ AO, has on facts and in law:

Excluding provision for doubtful debts in computing Book profits under section 115JB of the Income tax Act, 1961 (’the Act’):

1. erred in upholding the AO’s action of adding back the provisions for doubtful debts amounting to Rs. 11,29,70,000 to the book profits under clause (c) to Explanation 1 of section 115JB of the Act without appreciating the facts of the Appellant.

1.1. erred in not following the principles of Apollo Tyres Ltd. vs Commissioner of Income Tax, Kochi (255 ITR 273) wherein the Hon’ble Supreme Court of