“book profits”

The Bombay Dyeing and Manufacturing Company Limited, Mumbai vs. Income Tax Central Circle 2(1)(1), Mumbai

In the result, the appeal filed by the assessee is hereby allowed for statistical

Bench: Shri Om Prakash Kant, Jm & Ms. Kavitha Rajagopal, Am

assessee filed its return of income dated 30.11.2018 and had also filed its revised e-return on 31.03.2019 declaring total income at Rs.Nil and book profits at Rs.Nil u/s.115JB of the Act. The assessee's case was selected for complete scrutiny under the e-assessment scheme, 2019 on the following

Deputy Commissioner of Income Tax-2(2)(1), Mumbai, Aayakar Bhavan, Churchgate vs. Mumbai International Airport Limited, Mumbai

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokar

being investment written off while computing income under the normal provisions of the Act as well as while computing book profits under section 115JB of the Act. 5. The Ld. AR drew our attention to the relevant portion of the additional grounds placed in the paper book page No.11

Mumbai International Airport Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(2)(1), Mumbai

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

being investment written off while computing income under the normal provisions of the Act as well as while computing book profits under section 115JB of the Act. 5. The Ld. AR drew our attention to the relevant portion of the additional grounds placed in the paper book page No.11

Franklin Templeton International Services (India) P.Ltd, Mumbai vs. DCIT Cir 6(3)(1), Mumbai

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Rs.3,17,449/-, disallowance of repairs and maintenance expenses of Rs.29,47,184/-. The Ld.AO further made the disallowance of Section 14A while computing book profits u/s 115JB. Upon the receipt of the draft assessment order, assessee preferred objections before the DRP. 4.1 The DRP upheld the comparables selected ... passed the impugned order by making addition in the hands of the assessee at Rs.18,64,62,649/-. The Ld. AO also computed the book profits u/s 115JB of the Act by including the disallowance made u/s 14A. Assessment Year 2010-11 6. From the Transfer Pricing study report

Franklin Templeton International Services (India) P.Ltd, Mumbai vs. DCIT Cir 3(1), Mumbai

In the result, appeals filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Rs.3,17,449/-, disallowance of repairs and maintenance expenses of Rs.29,47,184/-. The Ld.AO further made the disallowance of Section 14A while computing book profits u/s 115JB. Upon the receipt of the draft assessment order, assessee preferred objections before the DRP. 4.1 The DRP upheld the comparables selected ... passed the impugned order by making addition in the hands of the assessee at Rs.18,64,62,649/-. The Ld. AO also computed the book profits u/s 115JB of the Act by including the disallowance made u/s 14A. Assessment Year 2010-11 6. From the Transfer Pricing study report

Dimple Realtors Private Limited, Mumbai vs. DCIT Circle 4(2)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2017-18 Dimple Realtors Private Limited, Deputy Commissioner Of Unit No. 210, Wing B, Income Tax, Western Edge Ii, Vs. Circle-4(2)(1), Borivali East, Aayakar Bhavan, Mumbai-400066. Marine Lines, Pan : Aaacd4136F Mumbai-400020. (Appellant) (Respondent) For Assessee : Shri J.P. Bairagra & Ms. Rupa Nanda For Revenue : Shri Annavaran Kosuri Date Of Hearing : 21-01-2026 Date Of Pronouncement : 16-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

assessee filed its return of income on 16-10- 2 2017, declaring total income at Rs. 45,39,359/- under the normal provisions and book profits u/s. 115JB of the Income Tax Act, 1961 („the Act‟) at Rs. 72,45,613/-. The case of the assessee was selected for complete

Bajaj International Realty Private Limited, Mumbai vs. DCIT-1(2), Mumbai

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

purpose of computing the expenditure relatable to exempt income while the purpose of computing the expenditure relatable to exempt income while computing the book profit under section 115JB of the Act. ng the book profit under section 115JB of the Act. 13. On the facts and in the circumstances ... loss at Rs. (-)1,59,99,289/- under normal provisions of normal provisions of the Income Tax Act, 1961 (in short Act) and declaring book profit u/s the Income Tax Act, 1961 (in short Act) and declaring book profit u/s the Income Tax Act, 1961 (in short Act) and declaring

Bajaj International Realty Private Limited, Mumbai vs. DCIT, 1(2)1, Mumbai

In the result both the appeals of the parties are partly allowed for In the result both the appeals of the parties are partly allowed for the statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

purpose of computing the expenditure relatable to exempt income while the purpose of computing the expenditure relatable to exempt income while computing the book profit under section 115JB of the Act. ng the book profit under section 115JB of the Act. 13. On the facts and in the circumstances ... loss at Rs. (-)1,59,99,289/- under normal provisions of normal provisions of the Income Tax Act, 1961 (in short Act) and declaring book profit u/s the Income Tax Act, 1961 (in short Act) and declaring book profit u/s the Income Tax Act, 1961 (in short Act) and declaring

Pba Infrastructure Limited, Mumbai vs. DCIT, Central Circle 5(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

income tax payable on the total income as computed under the normal provisions of the Act is less than the tax payable on the book profits u/s 115JB of the Act, then penalty under 271(1)(c) of the Act, is not attracted with reference to additions/disallowances made under normal

Pba Infrastructure Limited, Mumbai vs. DCIT, Central Circle 5(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

income tax payable on the total income as computed under the normal provisions of the Act is less than the tax payable on the book profits u/s 115JB of the Act, then penalty under 271(1)(c) of the Act, is not attracted with reference to additions/disallowances made under normal