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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

Birla Group Holdings Private Limited, Mumbai vs. Assisstant Commissioner of Income Tax (ACIT), Circle 2(1), Ujjain

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

ITA 2494/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Aug 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeethe Birla Group Holding Vs Acit, Circle 2(1), Ujjain Private Limited, (As A Aaykar Bhavan, 127, Dewas Road, Successor To Turquoise Bharatpuri, Ujjain, Madhya Investments & Finance Pvt Pradesh, 456010. Ltd) Industry House, 1St Floor, 159, Churchgate Reclamation, Marine Lines, Mumbai-400 020 Pan: Aaacr2250C Appellant Respondent

For Appellant: Shri Ronak Doshi & Pranav ZanwarFor Respondent: Shri Swapnil Choudhary – Sr AR
Section 10Section 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

M/S. Bodal Chemicals Ltd., Ahmedabad vs. The Dy.CIT, Circle-1, Ahmedabad

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR
Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

Assessing Officer observed that the assessee company paid tax under Section 115JB of the Income Tax Act, 1961. The Assessing Officer determined total book profit of Rs. 2,73,28,938/-. In the same assessment year, disallowances was made on account of late payment of provident fund ... Further, the Assessing Officer disallowed the assessee’s adjustment claim on account of brought forward losses on computation of MAT thereby stating that the book profit is an amount higher by Rs. 3,56,51,941/- and thus assessed the total income at Rs. 1,22,75,860/-. The Assessing

Writemen Media Private Limited, Bengaluru vs. Income Tax Officer, Ward-7(1)(3), Bengaluru

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

ITA 1516/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jul 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2014-15

For Appellant: Shri. Ravishankar, AdvocateFor Respondent: Shri. Ashwin D Gowda, Addl. CIT(DR)(ITAT), Bangalore
Section 115JSection 143(3)Section 153Section 56(2)(viib)

liability under MAT provisions u/s 115JB of the Act: i. The learned authorities below are not justified in adopting the assessed income as Book profit while computing the income u/s 115JB of the Act. ii. The learned authorities below failed to appreciate that the assessing officer has no power ... tinker with Book profits other than stated in the explanation to the section and considering the assessed income as Book profit is totally contrary to law and without jurisdiction on the facts and circumstance of the case. iii. Without prejudice, the learned authorities below erred in determination of tax liability

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4140/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 14ASection 80G

expenses incurred. In addition to this, the Assessing Officer made a corresponding adjustment by adding the disallowance under section 14A while computing the book profits under section 115JB of the Act. Both these disallowances under the regular provisions as well as under the MAT provisions were upheld by the Commissioner

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4139/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 14ASection 80G

expenses incurred. In addition to this, the Assessing Officer made a corresponding adjustment by adding the disallowance under section 14A while computing the book profits under section 115JB of the Act. Both these disallowances under the regular provisions as well as under the MAT provisions were upheld by the Commissioner

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4138/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 14ASection 80G

expenses incurred. In addition to this, the Assessing Officer made a corresponding adjustment by adding the disallowance under section 14A while computing the book profits under section 115JB of the Act. Both these disallowances under the regular provisions as well as under the MAT provisions were upheld by the Commissioner

ACIT Circle 6 1 1 Mumbai, Mumbai vs. M/S Cyquator Media Services Pvt Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4048/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Jul 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 143(3)Section 14ASection 14A(2)

relation to the disallowance made under section 14A read with Rule 8D 2 Cyquator Media Services Pvt. Ltd., and the corresponding disallowance while computing book profit under section 115JB. 3. The brief facts qua the issue involved are that the assessee company is engaged in selling of advertising space, subscriber ... Rule 8D of the Income Tax Rules, which was subsequently deleted by the learned CIT(A), both under the normal provisions and while computing book profits under section 115JB. 8. At the outset, it is imperative to underscore that the assessee had, on a suomoto basis, disallowed an amount

Raima Toll Road Private Limited, Mumbai vs. DCIT, Circle 3(1)(1), Mumbai

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

ITA 3380/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2018-19 Raima Toll Road Private Limited, Deputy Commissioner Of B1-406, Boomerang, Income Tax, Circle - 3(1)(1), Chandivali Farm Road, Mumbai Vs. Sakinaka, Mumbai - 400072 (Pan : Aagcr1492L) (Appellant) (Respondent) Present For: Assessee : Ms. Simran Dhawan, Advocate Revenue : Shri Annavaran Kosuri, Sr. Ar Date Of Hearing : 24.07.2025 Date Of Pronouncement : 31.07.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1075067439(1), Dated 26.03.2025 Passed Against The Assessment Order By The National E-Assessment Centre, Delhi, U/S. 143(3) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 14.04.2021 For Assessment Year 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Ms. Simran Dhawan, AdvocateFor Respondent: Shri Annavaran Kosuri, Sr. AR
Section 143(3)Section 250Section 80Section 801ASection 80I

assets of the eligible business, which is misplaced and factually incorrect as the writing off of Rs. 13.72 Cr reduced the book profits and that the same item was added back in computing the total income for the year under consideration making the entire exercise a revenue neutral and therefore

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 1(3)(1), Mumbai

ITA 6100/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Ms. Ramapriya Raghavan, CIT DR
Section 144C(5)

erred in denying a deduction of INR 6,16,548 claimed as per section 80G of the Act. Ground No. 4-Computation of book profits as per section 115JB of the Act and credit as per section 115JAA of the Act 4.1 Whether on the facts and circumstances ... case and in law, the Ld. AO, has erred in computing the book profit as per section 115JB of the Act and has erred in not granting appropriate credit under section 115JAA. Ground No. 5-Levy of interest under sections 234A and 234B of the Act 5.1 Whether

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Assessing Officer, New Delhi

ITA 3987/MUM/2024[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai & Shri Girish Agrawal

Section 144C(5)

erred in denying a deduction of INR 6,16,548 claimed as per Section 80G of the Act. Ground No. 4-Computation of book profits as per Section 115JB of the Act and credit as per Section 115JAA of the Act 4.1 Whether on the facts and circumstances ... case and in law, the Ld. AO, has erred in computing the book profit as per Section 115JB of the Act and has erred in not granting appropriate credit under Section 115JAA. Ground No. 5-Levy of interest under Sections 234A and 234B of the Act 5.1 Whether

ACIT Circle 3 3 1, Mumbai vs. Sicom Investments & Finance Limited, Mumbai

In the result the appeals filed by the revenue stands dismissed

ITA 5669/MUM/2024[2015]Status: DisposedITAT Mumbai30 Jul 2025

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

Section 10Section 10(38)Section 115Section 115JSection 143(2)Section 14A

circumstances of the case and in law, the Ld.CIT(A) erred in deleting Rs.28,49,528/- being disallowance u/s.14A to arrive at Book Profit u/s. 115JB of the act in accordance with clause (f) of Explanation 1 of Section 115JB of the Act?" 6. "The Appellant craves leave ... filed its return of income on 28/09/2015, declaring total income at Rs. 14,95,05,630/- under the normal provisions of the act and book profit u/s 115 JB at Rs. 12,61,56,779/-. The case was selected for scrutiny by issuing notices

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Aathmika Holdings Pvt Ltd, Chennai

In the result, the appeal of the Revenue stand dismissed and the

ITA 836/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 139(1)Section 142(1)Section 143(2)Section 56(2)(x)Section 92C

amount of income-tax claimed as refund, if any, to the extent of the excess over the tax payable with reference to the book profits in accordance with the law applicable thereto; (v) any amount representing provisions made for meeting liabilities, other than ascertained liabilities; (vi) any amount representing contingent

Bigstar Hotels Resorts Pvt. Ltd., New Delhi vs. ITO Ward 5(1), New Delhi

ITA 3351/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Jul 2025AY 2020-21

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

Section 143(3)Section 250

ITA No.3351/Del/2024 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "A" BENCH: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd), Mumbai vs. Assistant Commissioner of Income Tax Central Circle 8(1), Mumbai

In the result, the appeals filed by the assessee are

ITA 5423/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21
Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Limited ), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -8(1), Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

DCIT Central Circle 8(1), Mumbai vs. Mahadhan Agritech Limited, Pune

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3569/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd, Mumbai vs. Commissioner of Income Tax(Appeal)--50, Mumai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

Mahadhan Agritech Limited (Formerly Knwon As Smartech Technologies Ltd ), Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai-50, Mumbai

In the result, the appeals filed by the assessee are

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

Mahadhan Agritech Limited (Formerly Known As Smartech Technologies Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai.50, Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming addition of depreciation on goodwill and/or other intangible assets while computing book profit u/s 115JB of the Act. Ground 7 - That on the facts and in the circumstances of the case, the Ld. CIT (Appeals ... justified and grossly erred in confirming the addition of depreciation on the alleged inflated capital expenditure while computing book profit u/s 115JB of the Act. For AY 2017-18 Ground 1 - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified

Income Tax Officer 3(2)(1), Mumbai vs. Manas Agro Industries and Infrastructure Limited, Mumbai

In the result, the appeal of the revenue bearing ITA 1710/Mum/2024 is dismissed

ITA 1710/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeeincome-Tax Officer 3(2)(1), Vs Manas Agro Industries & Mumbai, Infrastructure Limited, 6Th Unit No.605, 6Th Floor, Raheja 673A, Floor, Aayakar Bhavan, Mumbai-400 020 Chambers, Nariman Point, Mumbai-400 021 Pan: Aaccf0662N Appellant Respondent

For Appellant: Shri Hitesh Shah (virtually appeared)For Respondent: Shri Leyaqat Ali Aafaqui – Sr.AR
Section 115JSection 143(3)Section 250Section 35D

Whether on the facts and circumstances of the case and in Law, the Ld CIT(A) was justified in disallowing the reworking of the book profit u/s 115JB by the AO". iii) The appellant prays that the order of the CIT(Appeals) on the above ground be set aside ... 35DD of the Act. The appeal on Ground Nos 1 to 2 are party allowed.” 5. In further argument related to re-computation of book profit under section 115JB of the Act, the Ld.AR stated that the deferred tax amount to Rs.70,02,985/- and unabsorbed depreciation amount to Rs.36