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“minimum alternate tax”

Special Rate ProvisionsSection 115JBSection 115JB222 judgments

The decision most relied on for minimum alternate tax is ACIT v. Vireet Investment Pvt. Ltd. (82 Taxmann.com 415), cited in 789 judgments on BharatTax.

Leading authorities on minimum alternate tax

ACIT v. Vireet Investment Pvt. Ltd.
82 Taxmann.com 415 · 2017 · High Court
789
citing judgments

Disallowance computed under Section 14A, read with Rule 8D, cannot be added to book profits under Section 115JB for Minimum Alternate Tax (MAT) purposes. Additionally, for Section 14A disallowance, only investments that yielded exempt income during the year are considered for calculating their average value.

Apollo Tyres Ltd. v. CIT
255 ITR 273 · 2002 · Supreme Court
657
citing judgments

For the purpose of computing book profits under Section 115J, arrears of depreciation, including those arising from assets working extra shifts, are a necessary charge on profits if debited to the profit and loss account and are allowable as such.

CIT v. Yokogawa India Ltd.
341 ITR 385 · 2012 · High Court
270
citing judgments

A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.

PCIT v. Ankit
416 ITR 591 · 2019 · High Court
125
citing judgments

Capital receipts, including interest subsidy received under schemes like TUF, are excluded when computing book profits under Section 115JB of the Income Tax Act. This principle also extends to the reduction of provisions written back from book profits for MAT purposes.

Ajanta Pharma Ltd. v. CIT
327 ITR 305 · 2010 · Supreme Court
85
citing judgments

Section 115JB is a self-contained code for computing book profit, which relies on audited financial statements subject to adjustments under Explanation 1. Restrictions on export profit deductions under Section 80HHC(1B) for normal tax computation do not automatically apply when computing book profits under Section 115JB.

CIT v. Echjay Forgings (P) Ltd.
251 ITR 15 · 2001 · High Court
75
citing judgments

Wealth tax paid by an assessee cannot be added back to net profit for the purpose of computing book profit under section 115J or section 115JB, as wealth tax is not included in the definition of 'income-tax' under the Explanation to these sections.

Indo Rama Synthetics (I) Ltd. v. CIT
330 ITR 363 · 2011 · Supreme Court
74
citing judgments

For Minimum Alternate Tax (MAT) under Section 115JB, the book profit must reflect the true working results of the company. Capital receipts that are not income cannot be included in book profit, and adjustments based on notes on accounts can be made to arrive at the real profit.

Rain Commodities Ltd. v. DCIT
41 DTR 449 · 2010 · ITAT
71
citing judgments

The ITAT Special Bench in Rain Commodities Ltd. held that certain capital receipts, such as forfeited share warrants, if credited to the profit and loss account, are liable for book profits tax under Section 115JB (Minimum Alternate Tax).

Judgments citing minimum alternate tax

Mobite Technologies Pvt. Ltd., Pune vs. ITO, Ward, 7(1), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1258/PUN/2025[2021-22]Status: DisposedITAT Pune10 Jul 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1258/Pun/2025 िनधा"रण वष" / Assessment Year: 2021-22 Mobite Technologies Private V The Income Tax Officer, Limited, S. Ward-7(1), Pune. A-701, Victoria Garden, Nagar Road, Kalyani Nagar, Pune – 411006. Maharashtra. Pan: Aafcm7197J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Smt. Shilpa Nc – Addl.Cit(Dr) Date Of Hearing 03/07/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-10, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 12.02.2025 For A.Y.2021-22, Emanating From The Order U/S.143(1) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Ao Cpc Has Erred In Rejecting Concessional Rate Of Income Tax Of 22% Adopted By Assessee For Calculation Of Tax Liability As Per Itr U/S 115Baa & The Ld. Cit A Erred In Confirming The Same

Section 115Section 115BSection 115JSection 143Section 143(1)Section 234BSection 250

erred in applying provisions of section 115JB and computing the MAT liability for the year 6. Alternatively, if the Minimum Alternate Tax (MAT) provisions under Section 115.JB are held applicable, the Assessee prays for allowance of MAT credit in accordance with the provisions

Aditya Birla Finance Limited, Mumbai vs. Assistant Commissioner of Income-Tax - 2(1)(1), Mumbai

In the result, the appeal is partly allowed

ITA 4821/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai08 Jul 2025

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar & Ms. S.Jayaram, ARsFor Respondent: Shri Rajesh Kumar Yadav, (CIT DR)
Section 135Section 143(3)Section 32Section 43BSection 80G

related to tax i.e., Advance Tax, Tax deducted at source, Tax credits (including but not limited to credits in respect of income tax, minimum alternate tax, sales tax, value added tax, turnover tax, minimum alternate tax, service tax, etc.), carry forward losses and unabsorbed depreciation, if any, in connection with

Jt. Cti (OSD), Circle-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 791/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

assessee. 40. As far as the issue of exclusion of sales tax benefit of Rs. 92,63,70,395/- from the computation of minimum alternate tax under the provisions of section 115JB is concerned, we note that the AO while assessing the income under normal provisions of the Act treated

Nirma Limited, Ahmedabad vs. DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 516/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

assessee. 40. As far as the issue of exclusion of sales tax benefit of Rs. 92,63,70,395/- from the computation of minimum alternate tax under the provisions of section 115JB is concerned, we note that the AO while assessing the income under normal provisions of the Act treated

The DCIT, Cir-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2224/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

assessee. 40. As far as the issue of exclusion of sales tax benefit of Rs. 92,63,70,395/- from the computation of minimum alternate tax under the provisions of section 115JB is concerned, we note that the AO while assessing the income under normal provisions of the Act treated

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2008/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

assessee. 40. As far as the issue of exclusion of sales tax benefit of Rs. 92,63,70,395/- from the computation of minimum alternate tax under the provisions of section 115JB is concerned, we note that the AO while assessing the income under normal provisions of the Act treated

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2007/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

assessee. 40. As far as the issue of exclusion of sales tax benefit of Rs.92,63,70,395/- from the computation of minimum alternate tax under the provisions of section 115JB is concerned, we note that the AO while assessing the income under normal provisions of the Act treated

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

In the result, appeal of the Assessee is partly allowed for statistical purposes

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

Appellant. 8. That on the facts and in the circumstances of the case and law, the Ld. AO erred in not granting appropriate Minimum Alternate Tax (MAT) credit at the time of determining the amount of tax payable by the Appellant. 9. That on the facts and in the circumstances

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 742/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2013-14

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 740/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 739/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2017-18

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 738/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 737/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2015-16

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 736/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

ACIT, Anand Circle, Anand vs. National Dairy Development Board, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 735/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

National Dairy Development Board, Anand vs. The Dy.CIT, Anand Circle, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 728/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

National Dairy Development Board, Anand vs. The Dy.CIT, Anand Circle, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 727/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2017-18
Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

National Dairy Development Board, Anand vs. The Dy.CIT, Anand Circle, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 726/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

National Dairy Development Board, Anand vs. The Dy.CIT, Anand Circle, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 725/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2015-16

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case

National Dairy Development Board, Anand vs. The Dy.CIT, Anand Circle, Anand

In the result, the appeals filed by the Revenue in ITA Nos

ITA 724/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 35DSection 36(1)Section 36(1)(viii)Section 37(1)

vide recent decision dated 06-09-2024 held as follows: “Section 115JB, read with section 2(26), of the Income-tax Act, 1961- Minimum alternate tax. Payment of Tax (Banks) Assessment years 2013-14 to 2015-16 Assessee-bank claimed that section 115JB would not be applicable in its case