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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

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 786/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR
Section 132Section 153ASection 56(2)(vii)

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 ... 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

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 785/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Apr 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR
Section 132Section 153ASection 56(2)(vii)

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 ... 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

Deputy Commissioner of Income Tax, Central Circle 6(3), Mumbai vs. Beil Infrastructure Limited, Gujarat

In the result, both the appeals of the revenue are dismissed

ITA 1759/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Apr 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Bharuch, Gujarat. During year under consideration assessee filed its return of income on 05/02/2021, declaring total income of Rs.49,80,69,530/- and declared book profits under 115J amounting to Rs.61,32,52,177/-. 2.1 The case was selected for scrutiny and assessee was called upon to furnished details ... difference between the provision and the amount actually spent could not be explained properly. The A.O. further added the excess provision to the book profit treating the same as unascertained liability for the computation of book profit u/s. 115JB of the Act The Hon'ble Rajasthan High Court

Theia Healthcare, Judge Colony 1 St Crossstreettambaram Sanatorium vs. Income Tax Officer, Chennai

The appeal stands dismissed

ITA 3225/CHNY/2024[2023-2024]Status: DisposedITAT Chennai29 Apr 2025AY 2023-2024

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.3225/Chny/2024 (िनधा'रण वष' / Assessment Year: 2023-24) M/S Theia Healthcare Income Tax Officer बनाम/ Plot No.10, Sf-1 Ncw 10(3), 2Nd Floor, Tamabaram Nungambakkam Vs. Sanatorium – 600047 Chennai - 600034 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aagft-2488-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Shri V.V.Rajkumar (Ca) – Ld. Ar " थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam (Jcit) – Ld. Sr. Dr

For Appellant: Shri V.V.Rajkumar (CA) – Ld. ARFor Respondent: Ms. Gouthami Manivasagam (JCIT) – Ld. Sr. DR
Section 115JSection 143(1)Section 80JSection 80P

accepted the returned income but raised a demand of Rs.1.95 Lacs by applying AMT. The AMT was to be applied @18.5% on adjusted book profits which worked out to be Rs.15.31 Lacs after adding back deduction as claimed by the assessee u/s 80JJAA for Rs.11.40 Lacs. The tax on adjusted ... book profit was worked out by CPC @18.5% which resulted into impugned demand against the assessee. The Ld. CIT(A), finding no error in the computation, dismissed the appeal against which the assessee is in further appeal before us. The Ld. AR has primarily contended that the aforesaid deduction

ACIT, Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

ITA 3705/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Apr 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 10ASection 115JSection 144BSection 144CSection 147Section 801B(9)

ground without going into the merits of the case viz. addition of Rs. 3,07,88,251/- for asset given on lease to the book profit u/s 115JB of the I.T. Act ignoring the fact that the Ld. CIT (A) had not decided the appeal on merit? 2.1 The grounds ... capital asset and hence, indexed loss on repayment / redemption of the said loan shall be allowed as long term capital loss. Adjustment to book profit u/s 115JB on account of principal portion of lease rent Reliance Industries Ltd 6 ITA No. 3705/MUM/2024 & CO No. 153/MUM/2024 14. erred in not adjudicating

Nuvama Wealth Management Limited, Bandra East, Mumbai vs. Deputy Comissioner of Income Tax, Cgo Building, Mumbai

ITA 480/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Apr 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

Section 1Section 115JSection 14A

Income Tax Act, 1961 (the Act) r.w.r. 8D of the Income Tax Rules, 1962 (the Rules). (ii) Addition made to the book profit under section 115JB of the Act towards the disallowance made under section 14A of the Act. 2. For the purpose of adjudication we will consider the facts ... income for AY 2018-19 on 30.11.2018 and a revised return on 29.03.2019 admitting a total loss of Rs.62,16,09,839/- and a book profit of Rs.9,49,48,746/-. The case was selected for scrutiny and statutory notices were duly served on the assessee. The Assessing Officer

Nuvama Wealth Management Limited, Bandra East, Mumbai vs. Deputy Comissioner of Income Tax, Cgo Building, Mumbai

ITA 479/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Apr 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Leyaqat Ali Aafaqui- Sr. DR
Section 115JSection 14A

Income Tax Act, 1961 (the Act) r.w.r. 8D of the Income Tax Rules, 1962 (the Rules). (ii) Addition made to the book profit under section 115JB of the Act towards the disallowance made under section 14A of the Act. 2. For the purpose of adjudication we will consider the facts ... revised return on 29.03.2019 admitting a total loss of Rs. 62,16,09,839/- and a book profit of Rs. 9,49,48,746/-. The case was selected for scrutiny and statutory notices were duly served on the assessee. The Assessing Officer (AO) during the course of assessment noticed that

Shree Yadvesh Transport Co . Pvt Ltd, Mumbai vs. ITO, Ward 13(2)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 6877/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Apr 2025AY 2016-17

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 115JSection 142(1)Section 143(2)Section 271(1)(c)Section 32

Appeals erred in upholding the action of the Assessing Officer of levying the penalty u/s 271(1)(c) when the income is assessed on book profit uls 115JB, tax on which is more than the tax on income determined in normal computation of tax. The Appellant submits that the penalty ... returns u/s 115 JB and therefore there is no loss to the revenue as tax has been paid u/s 115 JB on the book profits. It is submitted that assessee therefore did not revise the return of income as there was no liability to pay taxes under the normal provision

ACIT, Circle-2(2)(1), Bangalore vs. Canara Bank, Bengaluru

ITA 2058/BANG/2024[2021-2022]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-2022

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Vishal Bhat, CA
Section 11Section 115JSection 129Section 143(1)(a)Section 154

incorrect claim which attracted adjustment as specified under section 143(1)(a) of the Act with respect to addition of income tax provision to book profit under section 115JB of the Act amounting to Rs.11,49,64,55,264/-. The assessee submitted response disagreeing with the proposed adjustment ... adding the provision of Rs.45,66,54,00,000/- without considering def erredt tax of Rs.34,16,89,44,736/- and determining book profit of Rs.4,56,55,450/- and tax liability of Rs.7,97,86,58,688/-. Further, as the tax computed under section 115JB

Adp Private Limited, Hyderabad vs. DCIT, Circle-1(1), Hyderabad

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

ITA 194/HYD/2023[2014-15]Status: DisposedITAT Hyderabad15 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year: 2014-15 Vs. Deputy Commissioner Of Adp Private Limited, Income Tax, Hyderabad. Circle-1(1), Pan: Aanca8983A Hyderabad. (Appellant) (Respondent) Assessee By: Ca Kc Devdas, Ca Kranthi Palivela & Ca Mrudulatha Revenue By: M. Narmada, Cit-Dr Date Of Hearing: 04/02/2025 Date Of Pronouncement: 15/04/2025

For Appellant: CA KC Devdas, CA Kranthi PalivelaFor Respondent: M. Narmada, CIT-DR
Section 115JSection 143(3)Section 271(1)(c)

28/11/2014 declaring total income at Rs. 144,212,34,890/- under normal provisions of the Income Tax Act, 1961 (“the Act”) and book profits at Rs. 148,81,42,550/- U/s. 115JB of the Act. This is the second 3 round of litigation of the assessee. In the first round ... passed the draft assessment order on 24/03/2022 and determined the total income of the assessee at Rs. 171,32,40,363/- and book profit of Rs. 148,81,42,554/-. Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before the Ld. DRP. Accordingly, in compliance

ACIT(It)-3(2)(2), Mumbai vs. Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 5094/MUM/2024[2020-21]Status: DisposedITAT Mumbai15 Apr 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri P. J. Pardiwala / Jeet Kamdar
Section 37Section 40Section 44CSection 9(1)(vii)

hands of these entities in India and that the assessee has failed to deduct tax on the said payments. The AO while computing the book profits of the assessee added the amount of provision for unexpired risk which the assessee has disallowed while computing the income under the normal provisions ... Head Office. The CIT(A) deleted the disallowance made under section 40(a)(i) of the Act and the addition made to the book profits under section 115JB of the Act. Both the assessee and the revenue are in appeal against the order

ACIT(It)-3(2)(2) Mumbai, Mumbai vs. Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen, Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 5093/MUM/2024[2021-22]Status: DisposedITAT Mumbai15 Apr 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri P. J. Pardiwala / Jeet Kamdar
Section 37Section 40Section 44CSection 9(1)(vii)

hands of these entities in India and that the assessee has failed to deduct tax on the said payments. The AO while computing the book profits of the assessee added the amount of provision for unexpired risk which the assessee has disallowed while computing the income under the normal provisions ... Head Office. The CIT(A) deleted the disallowance made under section 40(a)(i) of the Act and the addition made to the book profits under section 115JB of the Act. Both the assessee and the revenue are in appeal against the order

Munchener Ruckversicherungs-Gesellschaft Aktiengesellschaft in Munchen, Mumbai vs. Deputy Commissioner of Income Tax (It)-3(2)(2), Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 4833/MUM/2024[2021-22]Status: DisposedITAT Mumbai15 Apr 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri P. J. Pardiwala / Jeet Kamdar
Section 37Section 40Section 44CSection 9(1)(vii)

hands of these entities in India and that the assessee has failed to deduct tax on the said payments. The AO while computing the book profits of the assessee added the amount of provision for unexpired risk which the assessee has disallowed while computing the income under the normal provisions ... Head Office. The CIT(A) deleted the disallowance made under section 40(a)(i) of the Act and the addition made to the book profits under section 115JB of the Act. Both the assessee and the revenue are in appeal against the order

Munchener Ruckversicherungs -Gesellschaft Aktiengesellschaft in Munchen, Mumbai vs. Deputy Commissioner of Income Tax (It)-3(2)(2), Mumbai

Accordingly, the grounds raised by the assessee are allowed

ITA 4832/MUM/2024[2021-22]Status: DisposedITAT Mumbai15 Apr 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri P. J. Pardiwala / Jeet Kamdar
Section 37Section 40Section 44CSection 9(1)(vii)

hands of these entities in India and that the assessee has failed to deduct tax on the said payments. The AO while computing the book profits of the assessee added the amount of provision for unexpired risk which the assessee has disallowed while computing the income under the normal provisions ... Head Office. The CIT(A) deleted the disallowance made under section 40(a)(i) of the Act and the addition made to the book profits under section 115JB of the Act. Both the assessee and the revenue are in appeal against the order

Naraya Securities Ltd., Delhi vs. DCIT, CC-1, Delhi

In the result, the appeal of the assessee is allowed

ITA 956/DEL/2023[2019-20]Status: DisposedITAT Delhi11 Apr 2025AY 2019-20

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumar

Section 115JSection 250Section 28

facts and circumstances of the case and in law the Ld. CIT(A) erred in directing the Ld. AO to recompute the book profits of the Appellant for the purposes of section 115JB after making addition of the aforesaid amount of Rs. 234,10,10,00/-thereto, failing to appreciate ... that book profits could have been adjusted on account of the above amount, being outside the ambit of adjustments provided in Explanations to section 115JB of the Act, which is self-contained.” 3. Briefly stated, the assessee company, in the financial year relevant to AY 2019-20, was engaged

Assistant Commissioner of Income Tax, C. R Building vs. The Oriental Insurance Co Ltd., Asaf Ali

In the result, the cross objections filed by the assessee are partly allowed for statistical purposes

ITA 3218/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Apr 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmanacit, Circle 10 (1), Vs. The Oriental Insurance Co. Ltd., New Delhi. A-25/27, Oriental House, Asaf Ali Road, Delhi Gate, New Delhi – 110 002. (Pan : Aaact0927R) Co No.152/Del/2023 (In Ita No.3218/Del/2023) (Assessment Year: 2018-19) The Oriental Insurance Co. Ltd., Vs. Acit, Circle 10 (1), A-25/27, Oriental House, New Delhi. Asaf Ali Road, Delhi Gate, New Delhi – 110 002. (Pan : Aaact0927R) (Appellant) (Respondent) Assessee By : Shri Tarandeep Singh, Advocate Shri Sandeep Yadav, Advocate Revenue By : Ms. Baljeet Kaur, Cit Dr Date Of Hearing : 23.01.2025 Date Of Order : 09.04.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Ms. Baljeet Kaur, CIT DR
Section 10Section 10(38)Section 115JSection 14ASection 44

computing sub-section (2) and (3) of Section 14A cannot be imported into clause (f) of Explanation to Section 115JA while computing adjusted book profit. In this regard, he referred to ITAT order in case of assessee for AY 2015-16 in ITA No. 5834/Del/2018 order dated ... Written Off of Rs.15,07,94,000/-. 4 That on facts and in law the CIT(A) has erred in upholding following adjustments to "Book Profits" returned by the respondent: (a) Disallowance of Provision for Standard Assets Rs.10,25,94,000/- (b) Disallowance of Depreciation of Rs.9

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 17/PUN/2024[2018-19]Status: DisposedITAT Pune07 Apr 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

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

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 16/PUN/2024[2017-18]Status: DisposedITAT Pune07 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.13 To 17/Pun/2024

Section 1Section 147Section 56(2)

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

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 15/PUN/2024[2016-17]Status: DisposedITAT Pune07 Apr 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

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

M/S Accord Mediplus Pvt Ltd, Pune vs. Income Tax Officer, Ward-1(1), Pune

ITA 14/PUN/2024[2015-16]Status: DisposedITAT Pune07 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. Phadke and Shri Piyush BafnaFor Respondent: Shri Chandra Vijay
Section 1Section 147Section 56(2)

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