ACIT CIRCLE 4.3.1, MUMBAI vs. JUST DIAL LTD, MUMBAI

ITA 486/MUM/2024Status: DisposedITAT Mumbai23 September 2024AY 2017-18Bench: SHRI. OM PRAKASH KANT (Accountant Member), SHRI. SANDEEP SINGH KARHAIL (Judicial Member)31 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee's appeal for AY 2017-18 concerning the disallowance of deferred tax asset for book profit computation under Section 115JB was allowed. The Tribunal also dismissed the Revenue's appeals for AY 2018-19, 2020-21, and 2021-22 on similar issues.

What were the facts?

The assessee claimed a deduction for deferred tax asset on demerger which was credited to other comprehensive income. The Assessing Officer disallowed this deduction for computing book profit under Section 115JB. The assessee argued that the deferred tax asset should be considered property under Section 115JB(2B) and thus ignored for book profit calculation.

What were the issues?

Whether deferred tax asset arising from a demerger, credited to other comprehensive income, is excludable from book profit computation under Section 115JB. Whether the Revenue's disallowances on ESOP expenses and lease straight-lining were justified.

Which sections of the Income-tax Act were involved?

Section 115JB,Section 2(19AA),Section 72A,Section 56(2)

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Cases cited in this judgment(4)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI. OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI. SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no. 254/Mum./2024 (Assessment Year :2017–2018) Just Dial Limited Palm Court Building M, 501/B, 5th Floor, New Link Road, Besides Goregaon Sports Club, Malad (West), Mumbai – 400064. PAN-AAACA8049G ……………. Appellant v/s

Deputy Commissioner of Income Tax Circle 4(3)(1), Mumbai Room No. 649, 6th Floor, Aayakar Bhavan, ……………. Respondent Maharishi Karve Road, Mumbai – 400020. ITA no. 486/Mum./2024 ITA no. 485/Mum./2024 (Assessment Year :2017–2018) (Assessment Year :2018–2019) ITA no. 484/Mum./2024 ITA no. 483/Mum./2024 (Assessment Year :2020–2021) (Assessment Year :2021–2022)

ACIT Circle 4.3.1 Aayakar Bhavan, M.K. Road, Churchgate ……………. Appellant Mumbai – 400020. v/s Just Dial Ltd 501/B, Palm Court Building M, New Link Road, Malad (West), Mumbai – 400064. ……………. Respondent PAN-AAACA8049G

Assessee by : Shri Madhur Agarwal, Ms. Moksha Mehta Revenue by : Shri Ankush Kapoor, CIT DR

Date of Hearing – 26/06/2024 Date of Order – 23/09/2024

ITAs No.254, 486, 485, 484, 483/MUM/2024 (A.Y.: 2017-18, 2018-19, 2020-21, 2021-22) Just Dial

The order continues below.

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