M/S. TOPGRAIN CORPORATE SERVICE PVT. LTD.,KOLKATA vs. I.T.O., WARD - 4(1),, KOLKATA

ITA 2276/KOL/2025Status: DisposedITAT Kolkata05 February 2026AY 2017-2018Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that disallowance under section 14A cannot be added back while computing book profit under section 115JB, citing previous judicial precedents. The addition made by the Assessing Officer and sustained by the CIT(A) under section 14A was deleted.

What were the facts?

The assessee filed a return declaring a total loss and book profit. The Assessing Officer made additions under section 14A read with Rule 8D to both total income and book profit. The CIT(A) partly allowed the appeal but upheld the additions to book profit and the disallowance under section 14A.

What were the issues?

Whether disallowance under Section 14A can be added to book profit under Section 115JB and whether interest under Sections 234B and 234C are also deleted consequent to deletion of addition.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB,Section 8D,Section 234B,Section 234C,Section 250,Section 10(34),Section 10(38)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH KOLKATA

Before: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Per Pradip Kumar Choubey, Judicial Member:

This appeal filed by the assessee is directed against the order dated 29.08.2025 of the Addl/JCIT(A)-1, Chennai (hereinafter referred to as the “CIT(A)”) passed u/s 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the assessment year 2017–18. 2. Brief facts of the case are that the assessee filed its return of income declaring total loss of Rs.40,527/- and Book Profit at Rs.4,49,73,148/-. Subsequently, the case of the assessee was taken up for

The order continues below.

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