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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

Jindal Saw Ltd., New Delhi vs. ACIT, Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 504/DEL/2022[2014-15]Status: DisposedITAT Delhi04 Jun 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

capital receipt and not chargeable to tax under normal provisions of Income tax. Further, we direct the AO to exclude the same from the book profits for the purpose of charging MAT u/s 115JB of the Act. Accordingly, Ground No.1 to 3 of the assessee are allowed. 56. Ground No.4 ... inadvertently offered to tax, being in the nature of a capital receipt not liable to tax, should be directed to be excluded while computing book profit under section 115JB of the Act." 63. The assessee in support of the additional grounds taken, filed written submissions which reads as under

DCIT Circle-13(2), New Delhi vs. Jindal Saw Ltd., New Delhi

In the result, assessee’s appeal in ITA No

ITA 4760/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

capital receipt and not chargeable to tax under normal provisions of Income tax. Further, we direct the AO to exclude the same from the book profits for the purpose of charging MAT u/s 115JB of the Act. Accordingly, Ground No.1 to 3 of the assessee are allowed. 56. Ground No.4 ... inadvertently offered to tax, being in the nature of a capital receipt not liable to tax, should be directed to be excluded while computing book profit under section 115JB of the Act." 63. The assessee in support of the additional grounds taken, filed written submissions which reads as under

Jindal Saw Ltd., New Delhi vs. ACIT Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 4693/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

capital receipt and not chargeable to tax under normal provisions of Income tax. Further, we direct the AO to exclude the same from the book profits for the purpose of charging MAT u/s 115JB of the Act. Accordingly, Ground No.1 to 3 of the assessee are allowed. 56. Ground No.4 ... inadvertently offered to tax, being in the nature of a capital receipt not liable to tax, should be directed to be excluded while computing book profit under section 115JB of the Act." 63. The assessee in support of the additional grounds taken, filed written submissions which reads as under

M/S. Globus Spirits Ltd., Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed with consequences to follow as per the determination above

ITA 3614/DEL/2017[2012-13]Status: DisposedITAT Delhi04 Jun 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Globus Spirits Ltd., Vs Dcit, F-0, Ground Floor, Circle-10(1), The Mira Corporate Suit, New Delhi. Ishwar Nagar, Mathura Road, Delhi. Pan: Aaacg2634B (Appellant) (Respondent) Assessee By : Shri Anil Kumar Chopra, Advocate & Shri Parveen Kumar, Ca Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.04.2025 Date Of Pronouncement : 04.06.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 25.11.2016 Of The Commissioner Of Income-Tax (Appeals)-35, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.20/15-16 Arising Out Of The Appeal Before It Against The Order Dated 20.03.2015 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Circle-10(1), New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Anil Kumar Chopra, Advocate &For Respondent: Shri Om Parkash, Sr. DR
Section 143(3)

aforesaid amount of Rs.1,10,000/- and Rs.23,655/-. 9. As regards the ground No.7, the same arises out of increase in book profits for making adjustment of Rs.1,05,006/- while computing income u/s 115JB of the Act on account of disallowance ... restrict the adjustment 5 to the extent of Rs.59,971/-. It is trite law that no adjustment can be made in the book profits for the purpose of MAT u/s 115JB of the Act and the Hon’ble jurisdictional High Court of Delhi and Special Bench of the Delhi Tribunal

Income Tax Officer, Ward-3(1), Hyderabad vs. Regency Ceramics Limited, Hyderabad

In the result, appeal filed by the Revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

ITA 1350/HYD/2024[1998-99]Status: DisposedITAT Hyderabad02 Jun 2025AY 1998-99

Bench: Us:

Section 115JSection 143(3)Section 33BSection 80HSection 80I

declaring an income of Rs. 5,26,22,429/- under the normal provisions (after claiming set off of brought forward losses) and “book profit” under Section 115JA of the Act at Rs. 1,63,35,580/-. Thereafter, the assessee company on 01/02/199 filed a revised return of income, wherein after ... deduction under Section 80IA r.w.s 33B of the Act as per clause (v) of subsection (2) of section 115JA of the Act the “book profit” under section 115JA was reduced to NIL. 4. Thereafter, the JCIT(Assessment), Special Range-6, Hyderabad framed the assessment vide his order passed under Section

Income Tax Officer, Ward-3(1), Hyderabad vs. Regency Ceramics Limited, Hyderabad

In the result, appeal filed by the Revenue being devoid and bereft

ITA 1340/HYD/2024[2002-2003]Status: DisposedITAT Hyderabad02 Jun 2025AY 2002-2003
Section 115JSection 143(3)Section 33BSection 80HSection 80I

declaring an income of Rs.5,26,22,429/- under the normal provisions (after claiming set off of brought forward losses) and “book profit” under Section 115JA of the Act at Rs. 1,63,35,580/-. Thereafter, the assessee company on 01/02/199 filed a revised return of income, wherein after raising ... deduction under Section 80IA r.w.s 33B of the Act as per clause (v) of subsection (2) of section 115JA of the Act the “book profit” under section 115JA was reduced to NIL. 4. Thereafter, the JCIT(Assessment), Special Range-6, Hyderabad framed the assessment vide his order passed under Section

Income Tax Officer, Ward-3 (1), Hyderabad vs. Regency Ceramics Limited, Hyderabad

In the result, appeal filed by the Revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

ITA 1339/HYD/2024[2001-2002]Status: DisposedITAT Hyderabad02 Jun 2025AY 2001-2002

Bench: Us:

Section 115JSection 143(3)Section 33BSection 80HSection 80I

declaring an income of Rs. 5,26,22,429/- under the normal provisions (after claiming set off of brought forward losses) and “book profit” under Section 115JA of the Act at Rs. 1,63,35,580/-. Thereafter, the assessee company on 01/02/199 filed a revised return of income, wherein after ... deduction under Section 80IA r.w.s 33B of the Act as per clause (v) of subsection (2) of section 115JA of the Act the “book profit” under section 115JA was reduced to NIL. 4. Thereafter, the JCIT(Assessment), Special Range-6, Hyderabad framed the assessment vide his order passed under Section

Income Tax Officer, Ward-3(1), Hyderabad vs. Regency Ceramics Limited, Hyderabad

In the result, appeal filed by the Revenue being devoid and bereft

ITA 1338/HYD/2024[2000-2001]Status: DisposedITAT Hyderabad02 Jun 2025AY 2000-2001
Section 115JSection 143(3)Section 33BSection 80HSection 80I

declaring an income of Rs.5,26,22,429/- under the normal provisions (after claiming set off of brought forward losses) and “book profit” under Section 115JA of the Act at Rs. 1,63,35,580/-. Thereafter, the assessee company on 01/02/199 filed a revised return of income, wherein after raising ... deduction under Section 80IA r.w.s 33B of the Act as per clause (v) of subsection (2) of section 115JA of the Act the “book profit” under section 115JA was reduced to NIL. 4. Thereafter, the JCIT(Assessment), Special Range-6, Hyderabad framed the assessment vide his order passed under Section

Income Tax Officer, Ward-3(1), Hyderabad vs. Regency Ceramics Limited, Hyderabab

In the result, appeal filed by the Revenue being devoid and bereft

ITA 1337/HYD/2024[1999-2000]Status: DisposedITAT Hyderabad02 Jun 2025AY 1999-2000
Section 115JSection 143(3)Section 33BSection 80HSection 80I

declaring an income of Rs.5,26,22,429/- under the normal provisions (after claiming set off of brought forward losses) and “book profit” under Section 115JA of the Act at Rs. 1,63,35,580/-. Thereafter, the assessee company on 01/02/199 filed a revised return of income, wherein after raising ... deduction under Section 80IA r.w.s 33B of the Act as per clause (v) of subsection (2) of section 115JA of the Act the “book profit” under section 115JA was reduced to NIL. 4. Thereafter, the JCIT(Assessment), Special Range-6, Hyderabad framed the assessment vide his order passed under Section

Seabird Marine Services Private Limited, Jamnagar vs. ACIT, Circle - 1, Jamnagar, Jamangar

ITA 83/RJT/2025[2017-18]Status: DisposedITAT Rajkot30 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

For Appellant: Shri S. N. Soparkar, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 114Section 115JSection 143(3)

normal computation of income at Rs 50,17,35,726/- against returned income of Rs. 49,85,50,620/- and determining the Book profit u/s 115JB of the Act at Rs. 45,58,90,530/-against Returned Book loss of Rs.28,40,37,610/-. 2. Grounds of Appeal in relation ... computation of book profit u/s 115JB Hon. CIT(A) erred in law as well as in facts in (i). confirming addition made by assessing officer of Rs. 73.99 crores to the book profits under Clause (1) of Explanation 1 to Section 115JB (2) of the Income

Deputy Commissioner of Income-Tax, Chennai vs. Indian Overseas Bank, Chennai

In the result, appeal filed by the revenue for AY 2021-22 is partly allowed for statistical purpose

ITA 377/CHNY/2024[2021-22]Status: DisposedITAT Chennai30 May 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./I.T.A.Nos.299 & 300/Chny/2024 (िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22) Vs Deputy Commissioner Of Income Indian Overseas Bank, 763, Anna Salai, Tax, Chennai-600 002. Non-Corporate Circle - 8, Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपीलसं./I.T.A.Nos.354 & 377/Chny/2024 (िनधा"रणवष" / Assessment Years: 2020-21 & 2021-22) Deputy Commissioner Of Income Vs Indian Overseas Bank, Tax, 763, Anna Salai, Non-Corporate Circle - 8, Chennai-600 002. Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. C.Naresh, C.A
Section 143(2)Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43BSection 90

relevant year. 7. The learned Commissioner of Income Tax (Appeals) erred in holding that the provisions u/s 115JB for computation of book profits are not applicable in respect of Banks which are governed by Banking Regulatory Act, 1949.” 33. Deduction u/s 36(1)(viia) based on advance outstanding

DCIT Non Corporate Circle-8, Chennai vs. Indian Overseas Bank, Chennai

In the result, appeal filed by the revenue for AY 2021-22 is partly allowed for statistical purpose

ITA 354/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 May 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./I.T.A.Nos.299 & 300/Chny/2024 (िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22) Vs Deputy Commissioner Of Income Indian Overseas Bank, 763, Anna Salai, Tax, Chennai-600 002. Non-Corporate Circle - 8, Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपीलसं./I.T.A.Nos.354 & 377/Chny/2024 (िनधा"रणवष" / Assessment Years: 2020-21 & 2021-22) Deputy Commissioner Of Income Vs Indian Overseas Bank, Tax, 763, Anna Salai, Non-Corporate Circle - 8, Chennai-600 002. Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. C.Naresh, C.A
Section 143(2)Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43BSection 90

relevant year. 7. The learned Commissioner of Income Tax (Appeals) erred in holding that the provisions u/s 115JB for computation of book profits are not applicable in respect of Banks which are governed by Banking Regulatory Act, 1949.” 33. Deduction u/s 36(1)(viia) based on advance outstanding

Indian Overseas Bank, Chennai vs. DCIT(A), Chennai

In the result, appeal filed by the revenue for AY 2021-22 is partly allowed for statistical purpose

ITA 300/CHNY/2024[2021-22]Status: DisposedITAT Chennai30 May 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./I.T.A.Nos.299 & 300/Chny/2024 (िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22) Vs Deputy Commissioner Of Income Indian Overseas Bank, 763, Anna Salai, Tax, Chennai-600 002. Non-Corporate Circle - 8, Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपीलसं./I.T.A.Nos.354 & 377/Chny/2024 (िनधा"रणवष" / Assessment Years: 2020-21 & 2021-22) Deputy Commissioner Of Income Vs Indian Overseas Bank, Tax, 763, Anna Salai, Non-Corporate Circle - 8, Chennai-600 002. Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. C.Naresh, C.A
Section 143(2)Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43BSection 90

relevant year. 7. The learned Commissioner of Income Tax (Appeals) erred in holding that the provisions u/s 115JB for computation of book profits are not applicable in respect of Banks which are governed by Banking Regulatory Act, 1949.” 33. Deduction u/s 36(1)(viia) based on advance outstanding

Indian Overseas Bank, Chennai vs. DCIT(A), Chennai

In the result, appeal filed by the revenue for AY 2021-22 is partly allowed for statistical purpose

ITA 299/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 May 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./I.T.A.Nos.299 & 300/Chny/2024 (िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22) Vs Deputy Commissioner Of Income Indian Overseas Bank, 763, Anna Salai, Tax, Chennai-600 002. Non-Corporate Circle - 8, Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपीलसं./I.T.A.Nos.354 & 377/Chny/2024 (िनधा"रणवष" / Assessment Years: 2020-21 & 2021-22) Deputy Commissioner Of Income Vs Indian Overseas Bank, Tax, 763, Anna Salai, Non-Corporate Circle - 8, Chennai-600 002. Chennai. Pan : Aaaci-1223-J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. C.Naresh, C.A
Section 143(2)Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43BSection 90

relevant year. 7. The learned Commissioner of Income Tax (Appeals) erred in holding that the provisions u/s 115JB for computation of book profits are not applicable in respect of Banks which are governed by Banking Regulatory Act, 1949.” 33. Deduction u/s 36(1)(viia) based on advance outstanding

ACIT-6(1)(1), Mumbi, Mumbai vs. Alok Industries Ltd., Mumbai

ITA 727/MUM/2025[2008-09]Status: DisposedITAT Mumbai30 May 2025AY 2008-09

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

Section 115JSection 143(3)Section 250

nature of compensation received on non-performance of energy generation is a capital receipt and the same is not to be included while computing book profit u/s.115JB of the Act. 4. Brief facts of the case are that the assessee company is engaged in the business of manufacturing of apparels ... total income of the assessee, where the addition on subsidy received under the Technology Upgradation Fund (TUF) scheme was included while computing the book profit u/s.115JB of the Act. 5. Aggrieved the assessee was in appeal before the first appellate authority, challenging the impugned addition

ACIT-6(1)(1), Mumbai vs. Alok Industries Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 726/MUM/2025[2006-07]Status: DisposedITAT Mumbai30 May 2025AY 2006-07

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

Section 115JSection 143(3)Section 250

nature of compensation received on non-performance of energy generation is a capital receipt and the same is not to be included while computing book profit u/s.115JB of the Act. 4. Brief facts of the case are that the assessee company is engaged in the business of manufacturing of apparels ... total income of the assessee, where the addition on subsidy received under the Technology Upgradation Fund (TUF) scheme was included while computing the book profit u/s.115JB of the Act. 5. Aggrieved the assessee was in appeal before the first appellate authority, challenging the impugned addition

ACIT-6(1)(1), Mumbai vs. Alok Industries Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 725/MUM/2025[2007-08]Status: DisposedITAT Mumbai30 May 2025AY 2007-08

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

For Appellant: Shri Nimesh VoraFor Respondent: MS. Deepa Hiray (Addl. CIT)
Section 115JSection 143(3)Section 250

nature of compensation received on non-performance of energy generation is a capital receipt and the same is not to be included while computing book profit u/s. 115JB of the Act. 4. Brief facts of the case are that the assessee company is engaged in the business of manufacturing ... total income of the assessee, where the addition on subsidy received under the Technology Upgradation Fund (TUF) scheme was included while computing the book profit u/s. 115JB of the Act. 5. Aggrieved the assessee was in appeal before the first appellate authority, challenging the impugned addition

ACIT-2(1)(1), Mumbai vs. Geecee Ventures Limited, Mumbai

The appeal is allowed for statistical purposes

ITA 4119/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year 2018-2019 law the Ld. CIT(A) erred in deleting the adjustment made in the computation of book profit. at Rs. 83,93,835/- by increasing the net profit as per P&L account by expenses related to except income as per clause ... read with Rule 8D of the Income Tax Rules 1962 [for short ‘IT Rules’]. The Assessing Officer also increase the Book Profits computed under Section 115JB of the Act by the aforesaid disallowance of INR.83,93,835/- made under section 14A of the Act. 6. Being aggrieved the Assessee preferred

Geecee Ventures Limited, Mumbai vs. DCIT, Circle 2(1)(1), Mumbai

The appeal is allowed for statistical purposes

ITA 3975/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

4119/Mum/2024 and C.O.No.205/Mum/2024 Assessment Year 2018-2019 law the Ld. CIT(A) erred in deleting the adjustment made in the computation of book profit. at Rs. 83,93,835/- by increasing the net profit as per P&L account by expenses related to except income as per clause ... read with Rule 8D of the Income Tax Rules 1962 [for short ‘IT Rules’]. The Assessing Officer also increase the Book Profits computed under Section 115JB of the Act by the aforesaid disallowance of INR.83,93,835/- made under section 14A of the Act. 6. Being aggrieved the Assessee preferred

DCIT Cir 6(1)(2), Mumbai vs. Biostach India Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is dismissed

ITA 3559/MUM/2016[2011-12]Status: DisposedITAT Mumbai30 May 2025AY 2011-12

Bench: Shri Sandeep Gosain & Smt. Renu Jauhriआयकर अपील सं./Ita No. 349/Mum/2016 (निर्धारण वर्ा / Assessment Year :2011-12) Biostadt India Limited V/S. Dcit 6(1), Mumbai Poonam Chambers, A बिधम Aayakar Bhavan, Mumbai- Wing, 6Th Floor, Dr. A. B. 400020 Road, Worli, Mumbai- 400018 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccb1830G Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Kirit KamdarFor Respondent: Shri Leyaqat Ali Aafaqui
Section 115Section 115JSection 14ASection 154Section 250Section 263Section 32Section 32(1)(iia)Section 80

that the disallowance under section 14A made by applying Rule BD should be added while computing the total income as per book profits under section 115JB of the Act 9. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in affirming ... 349/Mum/2016 & 3559/Mum/2016 A.Y. 2011-12 Biostodt India Ltd. 12. Ground No. 8: disallowance u/s 14A for the purpose of computing book profit u/s 115JB: Rs. 4,10,154/-. 12.1 The assessee has submitted that the disallowance u/s 14A should not be taken into account while computing the book profit