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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

DCIT-2(1)(1), Mumbai vs. Bank of Baroda

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4913/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

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

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

applicable on the issue of allowability of bad debts written off, disallowance u/s 14A and pension provided on actuarial valuation in computing the book profits. 4. On the facts and in the circumstances of the case and in law the Id. CIT(A) ought to have decided on the issue ... year under consideration dated 27.11.2015 declaring total income at Rs.4441,92,59,570/- under the normal provisions and Rs.3398,43,53,000/- under book profit u/s 115JB of the Act. The assessee’s case was selected for scrutiny and assessment was completed u/s 143(3) of the Act dated

DCIT-2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, both the appeals filed by the Revenue and both the cross objections

ITA 4869/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

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

For Appellant: Shri C. Naresh, ARFor Respondent: Shri Vimal Kumar Meena, (CIT DR)
Section 115JSection 143(3)Section 147Section 14ASection 244ASection 250Section 36(1)(viia)

applicable on the issue of allowability of bad debts written off, disallowance u/s 14A and pension provided on actuarial valuation in computing the book profits. 4. On the facts and in the circumstances of the case and in law the Id. CIT(A) ought to have decided on the issue ... year under consideration dated 27.11.2015 declaring total income at Rs.4441,92,59,570/- under the normal provisions and Rs.3398,43,53,000/- under book profit u/s 115JB of the Act. The assessee’s case was selected for scrutiny and assessment was completed u/s 143(3) of the Act dated

Diabetomics Medical Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, all the three appeals of the Assessee

ITA 2149/HYD/2025[2018-19]Status: DisposedITAT Hyderabad11 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao

For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR
Section 56(2)(viib)

claimed as refund under the Income-tax Act, 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 liabilities

Diabetomics Medical Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, all the three appeals of the Assessee

ITA 2148/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao

For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR
Section 56(2)(viib)

claimed as refund under the Income-tax Act, 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 liabilities

Diabetomics Medical Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, all the three appeals of the Assessee

ITA 2147/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao

For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR
Section 56(2)(viib)

claimed as refund under the Income-tax Act, 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 liabilities

Lifelong Real Estate Private Limited, Delhi vs. DCIT, Circle 13(1), Delhi

In the result, the Assessee’s appeal is allowed

ITA 2251/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Feb 2026AY 2017-18

Bench: Shri Sudhir Kumar & Mrs. Renu Jauhria.Yr. : 2017-18 Lifelong Real Estate Private Vs. Dcit, Circle 13(1), Limited, C.R. Building, 508, Saket District Centre, New Delhi Dlf South Court, Delhi – 110 017 (Pan: Aabcl4530E) (Appellant) (Respondent)

For Appellant: Shri Dinesh Gupta, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 115JSection 14A

business of real estate activities. Assessee filed return of income declaring its total income at Rs. 2,13,27,837/- and at book profit of Rs. 3,09,69,622/- as per the provisions of Section 115JB of the Income Tax Act. Assessment was completed at a total income ... thereby making an addition of Rs. 13,97,502/- under section 14A in normal income as well as increased the book profits for the calculation of MAT. In appeal, Ld. CIT(A) dismissed the appeal of the assessee. Aggrieved with the action of the Ld. CIT(A), assessee

Brajbhumi Nirmaan Private Limited, Salt Lake vs. ITO, Ward 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2605/KOL/2025[2015-2016]Status: DisposedITAT Kolkata10 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Akkal Dudhwewala, ARFor Respondent: Shri Madanappa Raghuveer, DR
Section 133(6)Section 143(2)Section 56(2)(viib)

claimed as refund under the Income-tax Act, 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 liabilities

Kmc Speciality Hospitals India Ltd., Trichy vs. DCIT, Circle-1, Tiruchirappalli

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

ITA 3012/CHNY/2025[2013-14]Status: DisposedITAT Chennai10 Feb 2026AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./Ita No.: 3012/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Kmc Speciality Hospitals India The Deputy Commissioner Ltd., Vs. Of Income Tax, No.6, Royal Road, Cantonment, Circle-1, Tiruchirapalli – 620 001. Tiruchirappalli. Pan: Aadcs 0189E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sathyamurthy, Ca ""यथ" क" ओर से/Respondent By : Shri Y. Sudarshan, Jcit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 10.02.2026

For Appellant: Shri Sathyamurthy, CAFor Respondent: Shri Y. Sudarshan, JCIT
Section 115JSection 143(3)Section 250Section 40A(3)

business of running super speciality hospital. The return of income for the assessment year 2013-14 was filed on 27.09.2013 declaring ‘nil’ income and book profits of Rs.1,31,32,608/- u/s.115JB of the Income Tax Act, 1961 (hereinafter the ‘Act’). Against the said return of income, assessment was completed

Deputy Commissioner of Income Tax, Chennai vs. M/S. Chemplast Sanmar Limited, Chennai

In the result, the appeal filed by the Revenue is partly-allowed for statistical purposes

ITA 2627/CHNY/2025[2017-18]Status: DisposedITAT Chennai06 Feb 2026AY 2017-18

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2627/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of Chemplast Sanmar Limited, Income Tax, Vs. 9, Cathedral Road, Non-Corporate Circle 8, Chennai - 600 086. Chennai Pan: Aaacc 3000F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Gouthami Manivasagam, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 06.02.2026

For Appellant: Ms. Gouthami ManivasagamFor Respondent: Shri R. Vijayaraghavan, Advocate
Section 115JSection 143(3)Section 14ASection 40A(7)Section 40A(7)(b)Section 40A(9)Section 43B

assessment year 2017-18 was filed on 29.11.2017 disclosing total income of Rs.348,62,24,143/- under normal provisions and also returned book profit u/s.115Jb of the Act of Rs.305,76,23,229/-. Against said return of income, assessment was completed by the AO vide order dated 27.12.2019 passed u/s.143 ... Rs.355,92,80,286/- and the same was set-off against the brought forward business loss and determined ‘nil’ income. However, assessed the book profits u/s. 115JB of the Act at Rs.311,77,00,807/-. While doing so, the AO made the following disallowances:- i. Disallowance of Provision for Gratuity

M/S. Topgrain Corporate Service Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2276/KOL/2025[2017-2018]Status: DisposedITAT Kolkata05 Feb 2026AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 10Section 10(34)Section 10(38)Section 11Section 115JSection 12Section 14Section 14ASection 234BSection 234C

Brief facts of the case are that the assessee filed its return of income declaring total loss of Rs.40,527/- and Book Profit at Rs.4,49,73,148/-. Subsequently, the case of the assessee was taken up for scrutiny. The Assessing Officer completed the assessment of the assessee by assessing ... Officer also assessed total income at Rs.4,50,71,645/- by adding Rs.98,497/- u/s 14A read with Rule 8D in the computation of book profit u/s 115JB. M/s Topgrain Corporate Service Pvt. Ltd 3. Aggrieved by the said order, the assessee filed an appeal before the CIT(A) wherein

Aromatrix Flora (P) Ltd., New Delhi vs. ACIT Circle 1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2100/DEL/2024[2011-12]Status: DisposedITAT Delhi04 Feb 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 80I

assessee company at INR 2,59,84,420/- as per normal provision of Act and INR 4,86,98,700/- as per book profit vide assessment order dated 26.12.2018 passed u/s 143(3)/147/148 of the Act. 3. Against the said order, assessee filed an appeal before ... accepted the said mistake and filed the revised return of income. Ld. AR further submits that since the assessee had paid taxes on the book profits, there is no loss to the revenue if deduction u/s 80-IC of INR 2,33,44,909/- was wrongly claimed. 6. Ld.AR further

The India Cements Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1708/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Feb 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 115JSection 143(3)Section 148

Equity. Transition amount includes all such amount (except amounts in capital reserve and security premium reserve). The transition amount is to be adjusted in book profits equally over a period of 5 years. [Section 115JB(2C)] 5. As prescribed, the cumulative effect of all adjustments arising from this restatement reflecting ... Book), and are further reflected in Form 29B (internal Page 5 / Page 1E of the Paper Book). 8. The ld.AR submitted that in computing book profits u/s.115JB of the Act for A.Y. 2017-18, the assessee applied section 115JB(2C) introduced by the Finance Act, 2017 to specifically neutralise

DCIT, Mumbai vs. Trent Limited, Mumbai

In the result, these grounds of appeal are

ITA 5242/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

Section 115JSection 143(3)Section 153Section 254(1)Section 40A(2)Section 92BSection 92C

recognised in the year of sale of gift vouchers. Disallowance of Discount on Gift Cards and Gift Vouchers Sold for computation of Book Profit under Section 115JB 8. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) erred in upholding ... disallowance of discount on Gift Cards and Gift Vouchers sold while computing book profit under section 115JB of the Act, without appreciating the fact that there was no specific finding in the assessment order for making addition while computing book profits under section 115JB

Trent Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(3)(1), Mumbai

In the result, these grounds of appeal are

ITA 5166/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

Section 115JSection 143(3)Section 153Section 254(1)Section 40A(2)Section 92BSection 92C

recognised in the year of sale of gift vouchers. Disallowance of Discount on Gift Cards and Gift Vouchers Sold for computation of Book Profit under Section 115JB 8. On the facts and in the circumstances of the case and in law, the Hon'ble CIT(A) erred in upholding ... disallowance of discount on Gift Cards and Gift Vouchers sold while computing book profit under section 115JB of the Act, without appreciating the fact that there was no specific finding in the assessment order for making addition while computing book profits under section 115JB

General Reinsurance Ag, Mumbai vs. Assistant Commissioner of Income Tax (Internatonal Taxation)-Range 2(3)(2), Mumbai

ITA 887/MUM/2023[2020-21]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 115BSection 144C(5)Section 9(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

General Reinsurance Ag, Cologne, Germany vs. Assistant Commissioner of Income-Tax (International Taxation) Circle - 2(3)(2), Mumbai

ITA 4691/MUM/2023[2021-22]Status: DisposedITAT Mumbai30 Jan 2026AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 115BSection 144C(5)Section 9(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

General Reinsurance Ag, Mumbai vs. Assistant Commissioner of Income Tax (Internatonal Taxation)-Range 2(3)(2), Mumbai

ITA 2448/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 115BSection 144C(5)Section 9(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

General Reinsurance Ag, Mumbai vs. Assistant Comm. of Income Tax (International Taxation)-Range 2(3)(2), Mumbai

ITA 2447/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 115BSection 144C(5)Section 9(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Fresenius Kabi Oncology Limited, New Delhi vs. Commissioner of Income Tax (Appeals)-26, New Delhi

The appeal of the assessee is allowed and the impugned reassessment order is quashed

ITA 2867/DEL/2025[2011-12]Status: DisposedITAT Delhi30 Jan 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwalfresenius Kabi Oncology Vs. Commissioner Of Income Limited, Tax (Appeals)-26, B-310, Som Datt Delhi Chambers-1, Bhikaji Cama Place, New Delhi "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcd 7720 L Appellant .. Respondent

For Appellant: Sh. Aditya Vohra, Adv &For Respondent: Ms. Indu Bala Saini, Sr. DR
Section 115JSection 143(3)Section 148Section 154

pharmaceutical products, and assessee had filed return of income declaring income of Rs.1,55,20,236/- under normal provisions of the Act and book profit of Rs.69,24,10,863/- under Section 115JB of the Act. The assessee had revised the return on 14.03.2013 wherein total income of Rs.1 ... declared under normal provisions of the Act and the book profit of Rs.61,94,88,824/- was declared u/s. 115JB of the Act. 2.1 The assessee’s return was selected for scrutiny and the assessment order dated 20.03.2015 u/s. 143(3) of the Act was passed wherein Assessing Officer assessed

Icra Limited, Delhi vs. The Deputy Commissioner of Income Tax, Circle-10(1), Cr Building, Ip Estate, Delhi

In the result, A.Y.2013-14 of Revenue’s appeal is dismissed and Assessee’s appeals for A

ITA 2723/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 14ASection 37(1)

order of the Ld. CIT(A) in sustaining the additional disallowance made u/s.14A r.w.r. 8D of IT Rules under normal provisions as well as book profits u/s.115 JB of the Act. 17. Identical issue had been decided by us for the A.Y.2013-14 in favour of the assessee in respect ... appeal for the A.Y. 2018-19. We order accordingly. 18. In so far the disallowance made u/s.14A r.w.r 8D while computing the book profits u/s.115JB of the Act is concerned we observe that the issue has been decided by the Special Bench of Delhi Tribunal in the case of ACIT