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“section 115JB MAT”

Special Rate ProvisionsSection 115JBSection 115JB6 judgments

DDIT, NEW DELHI vs. M/S. THE BANK OF TOKYO MITSUBISHI UFJ LTD., NEW DELHI

Appeal is dismissed

ITA 3756/DEL/2014[2006-07]Status: DisposedITAT Delhi13 Aug 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanasstt. Yr.: 2006-07

Section 115JSection 143(3)Section 44CSection 90

India by the Head Office and the Indian tax paid thereupon by the Head Office of Rs. 127,955,895 and applicability of Section 115JB MAT provisions; respectively. A perusal of the case file indicates that both these issues between the parties are very much recurring ones as the tribunal ... findings deleting deferred bank guarantee disallowance in question in very terms. 12. Coming to the Revenue’s second substantive ground seeking to invoke Section 115JB; MAT computation for the purpose of invoking provisions of wealth-tax to P&L A/c, we are of the considered view that once we have

M/S. THE BANK OF TOKYO-MITSUBISHI, UFJ LTD.,NEW DELHI vs. DDIT, NEW DELHI

ITA 3708/DEL/2014[2006-07]Status: DisposedITAT Delhi13 Aug 2025AY 2006-07
Section 115JSection 143(3)Section 44CSection 90

India by the Head Office and the Indian tax paid thereupon\nby the Head Office of Rs.127,955,895 and applicability of Section 115JB MAT\nprovisions; respectively. A perusal of the case file indicates that both these issues\nbetween the parties are very much recurring ones as the tribunal

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

ITA 3723/DEL/2013[2009-10]Status: DisposedITAT Dehradun23 May 2025AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

rejecting assessee’s claim of its income derived from sale of carbon credit as capital receipt under normal provision as well as under section 115JB MAT computation. The assessee accordingly succeeds on both these grounds in very terms. 12. The assessee’s 4th to 9th substantive grounds claim section 80IA ... derived from sale of carbon credits (supra) as not taxable under normal provisions as well as under section 115JB MAT computation, which already stand 18 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 decided against the department in our preceding detailed discussion in assessment year 2008-09. We accordingly

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

ITA 3064/DEL/2013[2007-08]Status: DisposedITAT Dehradun23 May 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

rejecting assessee’s claim of its income derived from sale of carbon credit as capital receipt under normal provision as well as under section 115JB MAT computation. The assessee accordingly succeeds on both these grounds in very terms. 12. The assessee’s 4th to 9th substantive grounds claim section 80IA ... derived from sale of carbon credits (supra) as not taxable under normal provisions as well as under section 115JB MAT computation, which already stand 18 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 decided against the department in our preceding detailed discussion in assessment year 2008-09. We accordingly

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

ITA 3929/DEL/2012[2008-09]Status: DisposedITAT Dehradun23 May 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

rejecting assessee’s claim of its income derived from sale of carbon credit as capital receipt under normal provision as well as under section 115JB MAT computation. The assessee accordingly succeeds on both these grounds in very terms. 12. The assessee’s 4th to 9th substantive grounds claim section 80IA ... derived from sale of carbon credits (supra) as not taxable under normal provisions as well as under section 115JB MAT computation, which already stand 18 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 decided against the department in our preceding detailed discussion in assessment year 2008-09. We accordingly

M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

ITA 3925/DEL/2012[2008-09]Status: DisposedITAT Dehradun23 May 2025AY 2008-09

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

Section 143(3)Section 801A

rejecting assessee’s claim of its income derived from sale of carbon credit as capital receipt under normal provision as well as under section 115JB MAT computation. The assessee accordingly succeeds on both these grounds in very terms. 12. The assessee’s 4th to 9th substantive grounds claim section 80IA ... derived from sale of carbon credits (supra) as not taxable under normal provisions as well as under section 115JB MAT computation, which already stand 18 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 decided against the department in our preceding detailed discussion in assessment year 2008-09. We accordingly