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“book profits”

Special Rate ProvisionsSection 115JBSection 115JB1,713 judgments

The decision most relied on for book profits is Godrej & Boyce Mfg. Co. Ltd. v. DCIT (328 ITR 81), cited in 1,183 judgments on BharatTax.

Leading authorities on book profits

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

ACIT v. Vireet Investment Pvt. Ltd.
165 ITD 27 · 2017 · ITAT
882
citing judgments

No disallowance under section 14A can be made while computing book profits under section 115JB unless the expenditure is debited to the profit and loss account and satisfies clause (f) of Explanation 1 to section 115JB(2).

Joint Investments Pvt. Ltd. v. CIT
372 ITR 694 · 2015 · High Court
803
citing judgments

Disallowance under section 14A of the Income Tax Act cannot exceed the actual amount of exempt income earned by the assessee. This principle also applies when computing book profits under section 115JB.

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.

Kedarnath Jute Mfg. Co. Ltd. v. CIT
82 ITR 363 · 1971 · Supreme Court
654
citing judgments

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

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.

Judgments citing book profits

M/S Gvk Jaipur Expressway Private Limited, Telangana vs. PCIT 2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

Admin) has further erred in ignoring the fact that ld. FAO, apart from making disallowance, has simultaneously made adjustment of the impugned amount in book profit computed u/s 115 JB. Thus the assessment order so passed by FAO is neither erroneous nor in any way prejudicial to the interest ... holding the same as unascertained liability. Appellant prays that periodic overlay is mandatory as per maintenance agreement and no adjustment was made in book profit computed u/s 115JB by the department in all preceding assessment years, completed u/s 143(3) where such disallowance was made in assessment order, therefore directions

DCIT, Jaipur vs. Gvk Jaipur Expressway Pvt Ltd, Jaipur

In the result, the appeal of the revenue for the years [A

ITA 307/JPR/2021[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: Us. Moreover, The Assessee Has Also Filed Cross Objections In Both The

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 14ASection 250Section 36(1)(va)Section 43B

made for all these grounds. Department further challenged the action of Ld. CIT(A) of holding that disallowance u/s 14A is not includible in Book profits for the purpose of charging MAT u/s 115JB of the Act. Brief facts are that ld. AO invoked the provision of Section ... appellant company, on the funds utilized for subscribing to the share capital in various group companies and further included the same in the book profits for computing the MAT u/s 115JB of the Act. Ld. CIT(A) has deleted the disallowance made u/s 14A and further held that the said

DCIT, Jaipur vs. Gvk Jaipur Expressway Pvt Ltd, Jaipur

In the result, the appeal of the revenue for the years [A

ITA 306/JPR/2021[2016-17]Status: DisposedITAT Jaipur19 Aug 2025AY 2016-17

Bench: Us. Moreover, The Assessee Has Also Filed Cross Objections In Both The

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 14ASection 250Section 36(1)(va)Section 43B

made for all these grounds. Department further challenged the action of Ld. CIT(A) of holding that disallowance u/s 14A is not includible in Book profits for the purpose of charging MAT u/s 115JB of the Act. Brief facts are that ld. AO invoked the provision of Section ... appellant company, on the funds utilized for subscribing to the share capital in various group companies and further included the same in the book profits for computing the MAT u/s 115JB of the Act. Ld. CIT(A) has deleted the disallowance made u/s 14A and further held that the said

Compact Agencies Pvt. Ltd., Kolkata vs. DCIT/ACIT, Circle 3(1), Kolkata

Appeal of the assessee is allowed

ITA 1259/KOL/2025[2018-2019]Status: DisposedITAT Kolkata13 Aug 2025AY 2018-2019

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250

erred in confirming the disallowance of Rs. 19,22,407/- u/s 14A of the Act made by AO while calculating the book profit u/s 115JB of the IT Act, 1961. 4.) That on the facts and in the circumstances of the case, Ld. CIT(A) erred in confirming the disallowance ... assessee: “5. Regarding the upward adjustment of disallowance computed under Section 14A 4 Compact Agencies Pvt. Ltd. of the Act for computing "book profit under Section 115JB of the Act. It is seen that for A.Y. 2015-16 the matter has been decided against the assessee

Didu Investments Private Limited, Kolkata vs. D.C.I.T., Circle-6(1), Kolkata

The appeal of the assessee is partly allowed

ITA 2585/KOL/2024[2014-15]Status: DisposedITAT Kolkata13 Aug 2025AY 2014-15

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 14ASection 250

also considered the total addition made by him u/s 14A of the Act for the purposes of calculating book profit u/s 115JB of the Act. 2 Didu Investments Private Limited 1.2 The assessee carried this matter in appeal where he could not succeed on the basis of the following finding ... justified in confirming the disallowance made by AO u/s 14A r.w.r. 8D(2) of Rs. 10,01,951/- while computing book profit under Sec. 115JB of the Act. 3. Without prejudice to the above, the Ld. CIT(A) erred in confirming the disallowance made by AO u/s 14A r.w.r

Sandhar Technologies Ltd., New Delhi vs. ACIT, Circle Ltu-1, New Delhi

In the result, both appeals of the assesses are partly allowed

ITA 7169/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Aug 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.7168 और 7169/िद"ी/2019(िन.व. 2015-16 और 2016-17)

For Appellant: S/Shri Salil Kapoor, Tarun Chanana, Utkarsa Gupta &For Respondent: Shri Manish Gupta, Sr. DR
Section 10Section 115JSection 143(3)Section 14ASection 35

assessee filed its return of income for AY 2015-16 declaring total income of Rs.42,37,18,910/- under normal provisions and book profit of Rs.53,44,51,020/- u/s. 115JB of the Act. During the period relevant to assessment year under appeal, the asseseee had entered into International Transactions ... others of Rs.7,95,004/- iii. Disallowance u/s. 14A of the Act Rs.3,01,621/-, disallowance u/s. 14A of the Act as part of book profits u/s. 115JB of the Act Rs.14,67,806/-. Aggrieved by the assessment order dated 28.12.2018 passed u/s. 143(3) of the Income

Sandhar Technologies Ltd., New Delhi vs. ACIT, Circle Ltu-1, New Delhi

In the result, both appeals of the assesses are partly allowed

ITA 7168/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Aug 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.7168 और 7169/िद"ी/2019(िन.व. 2015-16 और 2016-17)

For Appellant: S/Shri Salil Kapoor, Tarun Chanana, Utkarsa Gupta &For Respondent: Shri Manish Gupta, Sr. DR
Section 10Section 115JSection 143(3)Section 14ASection 35

assessee filed its return of income for AY 2015-16 declaring total income of Rs.42,37,18,910/- under normal provisions and book profit of Rs.53,44,51,020/- u/s. 115JB of the Act. During the period relevant to assessment year under appeal, the asseseee had entered into International Transactions ... others of Rs.7,95,004/- iii. Disallowance u/s. 14A of the Act Rs.3,01,621/-, disallowance u/s. 14A of the Act as part of book profits u/s. 115JB of the Act Rs.14,67,806/-. Aggrieved by the assessment order dated 28.12.2018 passed u/s. 143(3) of the Income

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

ITA 1185/BANG/2025[2018-19]Status: DisposedITAT Bangalore11 Aug 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K, JUDICIAL MEMBER

Raajratna Energy Holdings Private Limited, Hyderabad vs. Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

ITA 1184/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Aug 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K, JUDICIAL MEMBER

ACIT (Ltu)-1, Mumbai vs. Union Bank of India, Mumbai

In the result, appeal of the assessee is allowed

ITA 882/MUM/2020[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri C Naresh, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

case are that the assessee filed its return of income on 27/11/2015 declaring total income of Rs. 33,49,62,49,038/- and book profits of Rs.28,85,73,24,680/-. The return was selected for scrutiny assessment and accordingly statutory notices were issued and served upon the assessee. During ... present case of the assessees. Sub-section (1) of Section 115JB mandates charge of income based 17 I.T.A. No. 424/Mum/2020 I.T.A. No. 882/Mum/2020 on book profits subject of fulfilment of certain conditions and also provides that the same starts with non-obstante clause and therefore, it is a departure from

Income Tax Officer, Ward-1(3), Hyderabad vs. Bhagyanagar India Limited, Secunderabad

In the result, the appeal of the Revenue is dismissed

ITA 1200/HYD/2019[2016-17]Status: DisposedITAT Hyderabad08 Aug 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1200/Hyd/2019 (निर्धारण वर्ा/Assessment Year:2016-17) Income Tax Officer, M/S. Bhagyanagar India Ward-1(3), Hyderabad. Vs. Limited, Hyderabad. Pan:Aaacb8963C (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K.C. Devdas, C.A. रधजस् व द्वधरध/Revenue By: Shri Narender Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 24/07/2025 घोर्णध की तधरीख/Pronouncement: 08/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Hyderabad (“Ld. Cit(A)”), Dated 16.05.2019 For The A.Y. 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal:

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri Narender Kumar Naik
Section 115JSection 143(2)Section 143(3)Section 14ASection 37(1)Section 80

after claiming deduction under Section 80- IA of the Act to the extent of its gross total income, and reported book profit of Rs.1,78,69,216/- under Section 115JB of the Act. The case of the assessee was selected for complete scrutiny under CASS and accordingly, notice under Section ... amounting to Rs.1,23,56,803/-, the assessed total income under normal provisions of the Act remained Rs. nil. However, while computing book profit under Section 115JB of the Act, the Ld. AO made addition of Rs.75,59,818/- under Section 14A of the Act and Rs.2

Dy. Commissioner of Income Tax Circle 10(1), Delhi, Cr Building vs. Indus Towers Limited, Gurgram

ITA 2805/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

dated 08.05.2019 u/s 143(3) at a total income of INR 19,94,56,00,488/- under the normal provisions of the Act and book profit was assessed at INR 23,17,17,16,200/- after making various additions/disallowances. 4. Against this order, the assessee went in appeal before ... facts and in law in not directing that the aforesaid amount be excluded from income of assessment year 2015-16. Adjustments while computing book profits under section 115JB [MAT Provisions] 10. That the CIT(A) erred on facts and in law in upholding various adjustments made by the AO while

Indus Towers Ltd., Gurugram, Haryana vs. Deputy Commissioner of Income-Tax, Circle 12(1), New Delhi

ITA 2607/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

dated 08.05.2019 u/s 143(3) at a total income of INR 19,94,56,00,488/- under the normal provisions of the Act and book profit was assessed at INR 23,17,17,16,200/- after making various additions/disallowances. 4. Against this order, the assessee went in appeal before ... facts and in law in not directing that the aforesaid amount be excluded from income of assessment year 2015-16. Adjustments while computing book profits under section 115JB [MAT Provisions] 10. That the CIT(A) erred on facts and in law in upholding various adjustments made by the AO while

Sony India Private Limited, New Delhi vs. ACIT, Circle-22(2), Delhi

ITA 2052/DEL/2022[2018-19]Status: DisposedITAT Delhi08 Aug 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Nageshwar Rao, Advocate &For Respondent: Shri S.K. Jhadav, CIT-DR
Section 143(3)

returned income of INR 96,83,40,450/-. 2. That on the facts and in law, the Ld. AO has erred in computing the book profits of the appellant at INR 366,96,60,990 as against book profits of INR 306,38,29,828 as disclosed in return ... provision for diminution in value of asset thereby adding the same in computing taxable income under normal provisions of the Act and book profits under section 115JB of the Act respectively. Disallowance of expenditure on Corporate Social Responsibility (“CSR”) under section 115JB of the Act by treating it as apportion

Sony India Private Limited, New Delhi vs. ACIT, Circle-22(2), Delhi

ITA 1688/DEL/2022[2017-18]Status: DisposedITAT Delhi08 Aug 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Nageshwar Rao, Advocate &For Respondent: Shri S.K. Jhadav, CIT-DR
Section 143(3)

returned income of INR 96,83,40,450/- 2. That on the facts and in law, the Ld. AO has erred in computing the book profits of the appellant at INR 366,96,60,990 as against book profits of INR 306,38,29,828 as disclosed in return ... provision for diminution in value of asset thereby adding the same in computing taxable income under normal provisions of the Act and book profits under section 115JB of the Act respectively. Disallowance of expenditure on Corporate Social Responsibility (“CSR”) under section 115JB of the Act by treating it as apportion

Sony India Pvt. Ltd., New Delhi vs. ACIT Circle-24(1), New Delhi

ITA 9080/DEL/2019[2015-16]Status: DisposedITAT Delhi08 Aug 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Respondent: Shri S.K. Jhadav, CIT-DR
Section 143(3)

returned income of INR 96,83,40,450/-. 2. That on the facts and in law, the Ld. AO has erred in computing the book profits of the appellant at INR 366,96,60,990 as against book profits of INR 306,38,29,828 as disclosed in return ... provision for diminution in value of asset thereby adding the same in computing taxable income under normal provisions of the Act and book profits under section 115JB of the Act respectively. Disallowance of expenditure on Corporate Social Responsibility (“CSR”) under section 115JB of the Act by treating it as apportion

Osaka Alloys & Steel Private Limited, Jalandhar vs. DCIT/ACIT, Circle-1, Jld, Jalandhar

In the result, the appeal filed by the assessee is allowed

ITA 60/ASR/2025[2012-13]Status: DisposedITAT Amritsar07 Aug 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 115Section 115JSection 143(1)Section 154Section 154oSection 2(24)Section 250Section 250oSection 80I

Income Tax, Jalandhar is illegal, bad in law and without jurisdiction. 2. The CIT(A) has erred in appreciating that the calculation of book profit under section 115 JB is a debatable issue, and as such, it cannot be rectified under Section 154 of the Income Tax Act. Section ... subsidies amounting to Rs. 5,26,484/- are capital in nature and then erred in not giving the same treatment while working out book profit u/s 115JB. 5. The Ld. CIT(A) failed to correctly interpret that once a receipt is not classified as income under section

Essay Commercial Resources Private Limited, Mumbai vs. DCIT, Circle-2(4), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 6067/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Aug 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankaressay Commercial Resources V/S. Deputy Commissioner Of Private Limited बनाम Income Tax, Central Circle 16Th Floor, Tower 2A, One – 2(4), 1001, 10Th Floor, World Center, Senapati Bapat Pratishtha Bhavan, Old Marg, Mumbai 400 013, Cgo Annexe, Maharishi Maharashtra Karve Road, Mumbai – 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacce5161H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Ms.Prachi Mehta, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 115JSection 143(3)

Essay Commercial Resources Private Limited, Mumbai the Act provides for additions and disallowances to be made to the net profit for computing book profits under the provisions of MAT. Further, as per the said explanation, there is no provision to disallow depreciation except to the extent it pertains to revaluation

Sara International Private Limited, New Delhi vs. ACIT Circle 22(1), New Delhi

ITA 533/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Aug 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 115JSection 143(1)Section 143(2)

Cement, Agriculture & Textile Machinery & Allied Products. During assessment proceedings, Assessing Officer observed that assessee filed Form 29B along with its annexures for computation of book profit u/s 115JB of the Act and observed that assessee has deducted prior period items of Rs.2,14,05,190/- from its profit before ... duly disallowed the prior period expenses in its computation of income under normal provisions but has not added back these expenses to its book profits u/s 115JB of the Act. By relying on the decision of Hon'ble Kerala High Court in the case of Sree Bhagawathy Textiles

Shakuntala Sadanand Shet Legal Heir of Late Sadanand Sheshgiri Shet, Mumbai vs. Income Tax Officer Ward 22 3 6 Mumbai, Mumbai

In the result, the appeal of the assesse bearing ITA No

ITA 3616/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Aug 2025AY 2014-15

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

For Appellant: Shri Ronak Doshi & Pranav ZanwarFor Respondent: Shri Swapnil Choudhary – Sr AR
Section 10Section 10(2)(a)Section 115JSection 143(3)Section 234CSection 250Section 263

facts and circumstances of the case and in law, the CIT(A) erred in upholding the AO's order in adding to the book profits an amount of Rs. 8,97,32,308/- being the share of loss from partnership firm. 2. The Appellant prays that that the aforesaid addition ... pertaining to share of loss from partnership firm to the computation of book profits u/s 115JB be deleted. GROUND NO. II: - LEVY OF INTEREST U/S 234C AND 234D OF THE ACT: 1. The CIT(A) erred in upholding the AO's order in levying interest u/s.234C and 234D