“book profits”

Special Rate ProvisionsSection 115JBSection 115JB1,713 judgments

THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED,MUMBAI vs. INCOME TAX CENTRAL CIRCLE 2(1)(1), MUMBAI, MUMBAI

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

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm\Nand\Nms. Kavitha Rajagopal, Am\N\Nita No.5274/Mum/2025\N(Assessment Year: 2018-19)\Nm/S. The Bombay Dyeing And\Nmanufacturing Company Limited,\Nneville House, Jn Heredia Marg,\Nballard Estate,\Nmumbai - 400 001\Npan: Aaact2328K\Nvs.\Nnational Faceless Appeal Centre,\Ndelhi (Deputy Commissioner Of\Nincome Tax, Central Circle-2(1)(1),\Nmumbai - 400001\N(Appellant)\N(Respondent)\Nassessee By\N:\Nshri Yogesh Thar, A.R.\Nms. Sukanya Jairam, A.R &\Nshri Saurabh Surana, A.R.\Nrespondent By\N:\Nshri Leyaqat Ali Aafaqui, Sr. Ar\Ndate Of Hearing\N:\N22.12.2025\Ndate Of Pronouncement\N:\N18.03.2025\Norder\Nper Kavitha Rajagopal, J M:\Nthis Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned\Ncommissioner Of Income Tax (Appeals) [‘Ld. Cit(A)' For Short], National Faceless\Nappeal Centre (‘Nfac' For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'),\Npertaining To The Assessment Year (‘A.Y.' For Short) 2018-19.\N2.\Nthe Assessee Has Raised The Following Grounds Of Appeal:\N“1. Ground No. 1: Disallowance Of Rs. 4,65,28,171/- Under Section 14A Of The\Nact:\N1.

Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

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

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 5560/DEL/2024[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(1)Section 143(1)(a)Section 143(3)Section 80Section 80ISection 92C

after claiming deduction under section 80IA of the Act in respect of power generation units. The company has declared book profit u/s 115JB at INR 8,82,86,58,376/- and paid MAT on book profits. The case of the assessee was taken up for scrutiny and a reference under

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

return of income for A.Y. 2018-19 declaring total income at Rs. 13,25,33,541/- as per normal provisions of the Act and book profits of Rs. 68,20,48,545/- as per the provisions of section 115JB of the Act. The case of the assessee was taken ... energy certificates (RECs) amounting to 20,76,97,397/- which is in the nature of capital receipt/profits should also be excluded, while computing the book profits u/s 115JB of the Act. Reversal of Suo-moto disallowance made by the assessee

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

ITA 1289/HYD/2025[2010-11]Status: DisposedITAT Hyderabad13 Mar 2026AY 2010-11

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआयकर अपील सं / Ita No.1289/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2010-11) Granules India Limited Vs. Dcit- Circle -2(1) 15Th Floor, Granules Tower Signature Tower, Botanical Garden Road Sy. No. 6(P) Of Kondaput Kondapur, Hyderabad – 500084 Sy. No. 37 Of Kothaguda Telangana Opp. Botanical Gardens Serilingampalluy, R.R. District Pan: Aaacg7369K Hyderabad-500084, Telangana (अपीलाथी/ Appellant) (प्रत्यथी/ Respondent)

Section 10BSection 143(3)Section 148Section 154Section 271(1)(c)

tablets (FD), filed its return of income for the A.Y.2010-11 on 28.09.2010 declaring total income of Rs.10,55,64,805/- under normal provision and book profit of Rs.30,50,73,292/- under provisions of 115JB of the Act. The assessee had claimed exemption of Rs.10,22,92,474/- in respect ... under section 143(3) r.w.s. 92CA(3) of the Act, on 24.03.2014 and assessed the total income at Rs.10,61,67,685/- and the book profits at Rs.30,50,73,292/-. 8. The case has been, subsequently reopened under section 147 of the Act for the reasons recorded

DEPUTY COMMISSIONER OF INCOME TAX-2(2)(1), MUMBAI, AAYAKAR BHAVAN, CHURCHGATE vs. MUMBAI INTERNATIONAL AIRPORT LIMITED, MUMBAI

ITA 7035/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

being investment written off while\ncomputing income under the normal provisions of the Act as well as\nwhile computing book profits under section 115JB of the Act.\n5.\nThe Ld. AR drew our attention to the relevant portion of the\nadditional 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, MUMBAI

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

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

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.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

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

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18

For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR

Section 56(2)(vii)Section 56(2)(viib)

claimed as refund under\nthe Income-tax Act, to the extent of the excess over the tax payable\nwith reference to the book profits in accordance with the law\napplicable thereto;\n(v) any amount representing provisions made for meeting liabilities,\nother than ascertained liabilities;\n(vi) any amount representing

ORIENTAL HOTELS LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-5(1), CHENNAI

The appeal of the assessee is allowed for statistical purpose

ITA 2601/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Vikram VijayaraghavanFor Respondent: Shri. K. Ilaiyaraja, Addl. CIT

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 154Section 35D(8)(C)

twofold. One is regarding the disallowance u/s.14A r.w.r 8D for an amount of Rs.7,46,949/- both on normal computation as well as book profit computation u/s.115JB of the Act and the second is the refusal of the ld.CIT(A) to entertain the additional grounds before him. 5. Before ... Atria Power Corporation Ltd [2022] 142 taxmann.com 413 (SC). In addition, the assessee also submitted that the invocation of Rule 8D while computing the book profits u/s 115JB of the Act by Assessing Officer is without any basis, as upheld by the Special Bench in ACIT vs Vireet Investments

SUPREME TRACTORS PRIVATE LIMITED,HARYANA BHAWAN vs. DCIT, KATNI

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

ITA 51/JAB/2025[2016-17]Status: DisposedITAT Jabalpur27 Feb 2026AY 2016-17

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshraassessment Year: 2016-17 Supreme Tractors Pvt Ltd V. Dcit Katni, Madhya Pradesh 483501. Katni, Madhya Pradesh- 483501. Pan:Aajcs4013M (Appellant) (Respondent) Appellant By: Shri Sahil Gupta, Advocate Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 12 02 2026 Date Of Pronouncement: 27 02 2026 O R D E R

For Appellant: Shri Sahil Gupta, AdvocateFor Respondent: Shri N. M. Prasad, Sr. DR-1

Section 115JSection 234C

furnishing quarter wise details of Long-Term Capital. Whereas, under the MAT provisions total Capital Gain earned during the year is considered while computing Book Profit u/s 115JB. Therefore, the assessee company is bound to create a chart to calculate interest u/s 234C of the Income Tax Act, 1961, which ... payable under normal rates amounted to ₹2,81,456 (Rupees Two Lakh Eighty One Thousand Four Hundred Fifty Six). 2. That the book profit during the year under section 115JB was 81,33,535 (Rupees Eighty-One Lakh Thirty-Three Thousand Five Hundred Thirty-Five only), and the tax payable

MEASAGE.OSAKA ALLOYS AND STEEL (P) LTD,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, JALANDHAR

The appeal stand dismissed

ITA 347/ASR/2019[2013-14]Status: DisposedITAT Amritsar20 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm आयकर अपील सं. / Ita No.347/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Osaka Alloys & Steel (P) Ltd. Dcit Circle - Ii बनाम/ 428, Mota Singh Nagar, Jalandhar Jalandhar Punjab - 144001 C/O Bhagat & Co. (Ca) Vs. 16 Brij Nagar, Jalandhar, Punjab - 144001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-7097-G (अपीलाथ"/Appellant) (" थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Adjournment Request " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 03-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

For Appellant: Adjournment requestFor Respondent: Sh. Farhat Khan (CIT) - Ld. DR

Section 115JSection 143(3)Section 263Section 263(1)Section 264Section 80I

made certain disallowances and framed an assessment. Subsequently, Ld. Pr. CIT, upon perusal of case records, observed that the assessee worked out book profits of Rs.1,716/- after claiming deduction u/s 80IB for Rs.3,11,72,422/- which was not permissible deduction u/s 115JB. Such omission resulted in short computation ... book profit. The Ld. AO failed to work out correct book profits of the assessee. Accordingly, the assessee was show-caused. Though the assessee opposed the revision on various grounds, Ld. Pr. CIT invoked Explanation-2 to Sec. 263(1) to hold that the order was erroneous and prejudicial

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Section 133(6)Section 92D

passed the\nimpugned order by making addition in the hands of the assessee\nat Rs.18,64,62,649/-. The Ld. AO also computed the book profits\nu/s 115JB of the Act by including the disallowance made u/s\n14A.\n Assessment Year 2010-11\n6. 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

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

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

Section 133(6)Section 92D

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

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 31/DDN/2022[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

Section 143(3)Section 263Section 80Section 80I

total income of INR 6,84,04,420/- after claiming deduction u/s 80-IA of the Act of INR 948,40,76,282/-. The book profits was shown at INR 7,84,96,09,382/- and MAT of INR 1,67,52,32,236/- was paid. The case

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1,, BARODA

In the result, appeal filed by the assessee is allowed

ITA 903/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2011-12

Bench: The Itat. Considering The Same, The Order Passed By Itat Was Recalled & The Appeal Of The Assessee Fixed For Adjudication Afresh On Merits, Vide Order In Ma No.94/Ahd/2025, Dated 18.12.2025. The Present Appeal, Accordingly, Has Come Up For Hearing Before Us.

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Alpesh Parmar, CIT.DR

Section 115JSection 143(3)Section 263

Revenue for having wrongly allowed the assessee a claim of alleged unascertained liability amounting to Rs.5,24,57,202/- while computing its book profits liable to tax under the minimum alternate tax regime u/s.115JB of the Act. The Book Profits had been determined at Rs.3 ... amount of such liability i.e. Rs.5,24,57,202/- (2,62,28,601 + 2,62,28,601) was to be added back to the books profit u/s.115JB of the Act. 5. The said facts find mention at para 2.1 of the order of the Ld.PCIT as under: “2.1 On verification

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

ITA 7260/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

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 :

For Appellant: Shri J.P. Bairagra &For Respondent: Shri Annavaran Kosuri

Section 115JSection 143(2)Section 143(3)Section 40A(2)(b)

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

M/S. BODAL CHEMICALS LIMITED,AHMEDABAD vs. THE DY.CIT., CENTRAL CIRCLE-1(1),, AHMEDABAD

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

ITA 104/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Alpesh Parmar, CIT (DR)

Section 250Section 35(1)(ii)Section 80Section 801ASection 80A(5)Section 80I

Court, have held such incentives to be capital receipts not chargeable to tax. It is further submitted that capital receipts cannot be included in book profits under section 115JB, as held by the Calcutta High Court in Ankit Metal and Power Ltd. Therefore, the incentives deserve to be excluded from

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

ITA 5321/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

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

For Appellant: Shri Leyaqat Ali Aafaqui, Sr. ARFor Respondent: Shri Kirit Kamdar

Section 4Section 43C

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

ITA 5319/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Feb 2026AY 2018-19

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

For Appellant: Shri Leyaqat Ali Aafaqui, Sr. ARFor Respondent: Shri Kirit Kamdar

Section 4Section 43C

PBA INFRASTRUCTURE LIMITED ,MUMBAI vs. DCIT, CENTRAL CIRCLE 5(1), MUMBAI

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

ITA 4212/MUM/2025[2003-04]Status: DisposedITAT Mumbai13 Feb 2026AY 2003-04

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR a/w

Section 115JSection 143(3)Section 271Section 271(1)(c)

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

ITA 4211/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR a/w

Section 115JSection 143(3)Section 271Section 271(1)(c)

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