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“book profits”

Special Rate ProvisionsSection 115JBSection 115JB1,713 judgments

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

Leading authorities on book profits

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

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

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

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

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

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

ACIT v. Vireet Investment Pvt. Ltd.
82 Taxmann.com 415 · 2017 · High Court
789
citing judgments

Disallowance computed under Section 14A, read with Rule 8D, cannot be added to book profits under Section 115JB for Minimum Alternate Tax (MAT) purposes. Additionally, for Section 14A disallowance, only investments that yielded exempt income during the year are considered for calculating their average value.

Apollo Tyres Ltd. v. CIT
255 ITR 273 · 2002 · Supreme Court
657
citing judgments

For the purpose of computing book profits under Section 115J, arrears of depreciation, including those arising from assets working extra shifts, are a necessary charge on profits if debited to the profit and loss account and are allowable as such.

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

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

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

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

CIT v. Yokogawa India Ltd.
341 ITR 385 · 2012 · High Court
270
citing judgments

A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.

Judgments citing book profits

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

ITA 13/PUN/2024[2014-15]Status: DisposedITAT Pune07 Apr 2025AY 2014-15

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

Assistant Commissioner of Income Tax, Madurai vs. Ramco Industries Limited, Chennai

Appeals of the revenue are dismissed

ITA 2901/CHNY/2024[2013-14]Status: DisposedITAT Chennai07 Apr 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकरअपीलसं./I.T.A.No.2900 & 2901/Chny/2024 (निर्धारण वर्ष / Assessment Year: 2011-12 & 2013-14)

Section 115JSection 143(3)Section 14ASection 263

part of total income". (5) The Ld. CIT(A) erred in holding that disallowance w/s 14A r.w.Rule 8D should not be made while computing Book Profit u/s 115JB. (6) The Ld.CIT(A) failed to consider that the decision of the Hon'ble ITAT, Mumbai Bench in the case of DCIT ... been held that the addition on account of disallowance u/s. 14A r.w.Rule 8D being expenditure in relation to earning of exempt income to Book Profit u/s I 15JB is justified. (7) For these and such other grounds that may be adduced at the time of hearing and it is prayed

Assistant Commissioner of Income Tax, Madurai vs. Ramco Industries Limited, Chennai

Appeals of the revenue are dismissed

ITA 2900/CHNY/2024[2011]Status: DisposedITAT Chennai07 Apr 2025

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr.V.Justin, CITFor Respondent: Mr. S.Muralidhar, FCA &
Section 115JSection 143(3)Section 144Section 14ASection 263

part of total income" (5) The Ld. CIT(A) erred in holding that disallowance w/s 14A r.w.Rule 8D should not be made while computing Book Profit u/s 115JB. (6) The Ld.CIT(A) failed to consider that the decision of the Hon'ble ITAT, Mumbai Bench in the case of DCIT ... been held that the addition on account of disallowance u/s. 14A r.w.Rule 8D being expenditure in relation to earning of exempt income to Book Profit u/s I 15JB is justified. (7) For these and such other grounds that may be adduced at the time of hearing and it is prayed

M/S. Bank of Baroda(Erstwhile Vijaya Bank), Mumbai vs. Addl.CIT, Ltu, Bangalore

ITA 234/BANG/2025[2015-16]Status: DisposedITAT Bangalore04 Apr 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Smt. Lalitha Rameshwaran, A.RFor Respondent: Sri Rajashekhar M., D.R
Section 115JSection 143(2)Section 250Section 36(1)(vii)

Appellant Bank. 4. Without prejudice to the above, the learned CIT(A) erred in adding various items to arrive at the book-profit which are beyond the scope of the section. ITA No.234/Bang/2025 Bank of Baroda (Erstwhile Vijaya Bank), Mumbai Page 2 of 16 3. The brief facts ... regular provisions and also held that the provisions of section 115JB of the Act was applicable to the assessee bank and determined the book profit at Rs.447,95,02,243/-. 3.1 Thereafter, the assessee bank preferred an appeal against the said original assessment order before

DCIT, Central Circle- 3(2), Mumbai vs. Aarti Industries Limited, Mumbai

ITA 4537/MUM/2024[2014-15]Status: DisposedITAT Mumbai04 Apr 2025AY 2014-15

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Vijay MehtaFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.DR
Section 2(24)Section 80I

Ground No.5 and 6 urged by the Revenue is challenging the decision of the Ld.CIT(A) in excluding the fertilizer subsidy for computing book profit u/s.115JB of the Act. 7. 1. We heard the parties on this issue and perused the record.We notice that the Ld.CIT(A) has followed ... DCIT, ITA No. 1017/Mum/2017, dt. 21-05-2018 and held that the capital receipts should not be included for the purpose of computing book profits u/s.115JB of the Act. Since the Ld.CIT(A) has followed the binding decision rendered by the Hon'ble Bombay High Court in the case

DCIT, Central Circle 3(2), Mumbai vs. Aarti Industries Limited, Mumbai

In the result, all the four appeals filed by the Revenue are dismissed

ITA 4535/MUM/2024[2012-13]Status: DisposedITAT Mumbai04 Apr 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Vijay MehtaFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.DR
Section 2(24)Section 80I

Ground No.5 and 6 urged by the Revenue is challenging the decision of the Ld.CIT(A) in excluding the fertilizer subsidy for computing book profit u/s. 115JB of the Act. 7.1. We heard the parties on this issue and perused the record.We notice that the Ld.CIT(A) has followed ... DCIT, ITA No. 1017/Mum/2017, dt. 21-05-2018 and held that the capital receipts should not be included for the purpose of computing book profits u/s. 115JB of the Act. Since the Ld.CIT(A) has followed the binding decision rendered by the Hon’ble Bombay High Court in the case

DCIT, Central Circle 3(2), Mumbai vs. Aarti Industries Limited, Mumbai

In the result, all the four appeals filed by the Revenue are dismissed

ITA 4534/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Apr 2025AY 2013-14

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Vijay MehtaFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.DR
Section 2(24)Section 80I

Ground No.5 and 6 urged by the Revenue is challenging the decision of the Ld.CIT(A) in excluding the fertilizer subsidy for computing book profit u/s. 115JB of the Act. 7.1. We heard the parties on this issue and perused the record.We notice that the Ld.CIT(A) has followed ... DCIT, ITA No. 1017/Mum/2017, dt. 21-05-2018 and held that the capital receipts should not be included for the purpose of computing book profits u/s. 115JB of the Act. Since the Ld.CIT(A) has followed the binding decision rendered by the Hon’ble Bombay High Court in the case

DCIT, Central Circle 3(2), Mumbai vs. Aarti Industries Limited, Mumbai

In the result, all the four appeals filed by the Revenue are dismissed

ITA 4533/MUM/2024[2011-12]Status: DisposedITAT Mumbai04 Apr 2025AY 2011-12

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Vijay MehtaFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.DR
Section 2(24)Section 80I

Ground No.5 and 6 urged by the Revenue is challenging the decision of the Ld.CIT(A) in excluding the fertilizer subsidy for computing book profit u/s. 115JB of the Act. 7.1. We heard the parties on this issue and perused the record.We notice that the Ld.CIT(A) has followed ... DCIT, ITA No. 1017/Mum/2017, dt. 21-05-2018 and held that the capital receipts should not be included for the purpose of computing book profits u/s. 115JB of the Act. Since the Ld.CIT(A) has followed the binding decision rendered by the Hon’ble Bombay High Court in the case

Gujarat Urja Vikas Nigam Limited, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

The appeal of the assessee is allowed

ITA 507/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad02 Apr 2025AY 2012-13

Bench: Dr. Brr Kumar & Ms. Suchitra Kamble

For Appellant: Shri Manish J Shah & Shri Jimi Patel, A.RsFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 10(34)Section 115JSection 143(1)Section 143(3)

Assessing Officer in not allowing any relief whatsoever in respect of the Prior Period Income amounting to Rs.61,97,000/- while computing the Book Profits under section 115JB of the I T Act, 1961. The learned Commissioner of Income Tax (Appeals) ought to have appreciated additions made to the Book ... and/or disallowances. The total income was enhanced before set off of business losses of earlier years in normal courses of income as well as book profit computed under Section 115JB of the Act. 4. Aggrieved by the assessment order and the consequent additions made to the total income

Asst Commissioner of Income Tax, Circle 1, Ltu 1, Chennai, Nungambakkam vs. Chennai Petroleum Corporation Limited, Chennai

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

ITA 1835/CHNY/2024[2016-17]Status: DisposedITAT Chennai02 Apr 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1835/Chny/2024 िनधा;रण वष; /Assessment Year: 2016-17

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 115JSection 147

cost savings on crude freight through single point mooring on the ground that it is unascertained liability and the assessee itself while computing the book profit u/s. 115JB of the Act has considered this amount for disallowance being unascertained liability. The assessee has explained that the expenditure has been incurred ... amount through an entry called provision for capital loss. The assessee also explained that this amount was added back in the computation under the book profit u/s.115JB of the Act as a diminution in value of investments, which was required to be added back and disallowed Explanation u/s. 115JB

ACIT, New Delhi vs. M/S. Bhushan Steel Ltd., New Delhi

In the result, appeal of the assessee is allowed

ITA 1470/DEL/2016[2009-10]Status: DisposedITAT Delhi02 Apr 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2006-07] S. C. Johnson Pvt. Ltd., Vs Dcit, 5Th Floor, Plot No.68, Circle-7(1), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2007-08] S. C. Johnson Pvt. Ltd., Vs Acit, 5Th Floor, Plot No.68, Circle-22(2), Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent [Assessment Year : 2008-09] S. C. Johnson Pvt. Ltd., Vs Add.Cit, 5Th Floor, Plot No.68, Special Range-8, Sector-44, Gurugram, New Delhi Haryana-122003. Pan-Aaacl3128M Appellant Respondent Appellant By Shri K. M. Gupta, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 02.06.2025 Date Of Pronouncement 28.08.2025

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 250Section 80I

assessee, the re-assessment order was passed on 30.03.2014 wherein income of the assessee was computed at NIL under Income Tax Act and book profit of the assessee was assessed at INR 69,62,80,147/- as against the book loss declared at INR 15,58,74,356/-. 5. Aggrieved ... erred in upholding the adjustment done by the Ld. AO for a sum of Rs. 85,21,54.503/- in the book profits of the company for the purpose of computation of income under section 115.JB of the Act. 3.1 That the Ld. CIT(A) erred in confirming action

M/S. Munjal Auto Industries Ltd., Baroda vs. The Income Tax Officer, Ward-4(1), Baroda

Appeal is dismissed

ITA 784/AHD/2013[2003-04]Status: DisposedITAT Ahmedabad25 Mar 2025AY 2003-04

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Waghe Prasadrao, Sr.DR
Section 115JSection 43(1)

cost of fixed assets, its impact on depreciation computation under Section 43(1) of the Act, and its implications for the determination of book profits under Section 115JB. 2.9. Following appeals have now been reconstructed and listed for adjudication - ITA No. Assessment Appellant Amount in Year Dispute (Rs.) 784/Ahd/2013 ... each other. 1. The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in recomputing the book profit u/s. 115JB of the Act. 2. The learned CIT(A) erred in fact and in law in holding that the amount of sales

The DCIT, Circle-4, Vadodara vs. M/S. Munjal Auto Industries Ltd., Vadodara

Appeal is dismissed

ITA 1383/AHD/2009[2006-07]Status: DisposedITAT Ahmedabad25 Mar 2025AY 2006-07

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Waghe Prasadrao, Sr.DR
Section 115JSection 43(1)

cost of fixed assets, its impact on depreciation computation under Section 43(1) of the Act, and its implications for the determination of book profits under Section 115JB. 2.9. Following appeals have now been reconstructed and listed for adjudication - ITA No. Assessment Appellant Amount in Year Dispute (Rs.) 784/Ahd/2013 ... each other. 1. The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in recomputing the book profit u/s. 115JB of the Act. 2. The learned CIT(A) erred in fact and in law in holding that the amount of sales

The DCIT, Circle-4, Vadodara vs. M/S. Munjal Auto Industries Ltd., Vadodara

Appeal is dismissed

ITA 1382/AHD/2009[2003-04]Status: DisposedITAT Ahmedabad25 Mar 2025AY 2003-04

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Waghe Prasadrao, Sr.DR
Section 115JSection 43(1)

cost of fixed assets, its impact on depreciation computation under Section 43(1) of the Act, and its implications for the determination of book profits under Section 115JB. 2.9. Following appeals have now been reconstructed and listed for adjudication - ITA No. Assessment Appellant Amount in Year Dispute (Rs.) 784/Ahd/2013 ... each other. 1. The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in recomputing the book profit u/s. 115JB of the Act. 2. The learned CIT(A) erred in fact and in law in holding that the amount of sales

The DCIT, Circle-4, Vadodara vs. Munjal Auto Industries Ltd., Vadodara

Appeal is dismissed

ITA 1619/AHD/2008[2005-06]Status: DisposedITAT Ahmedabad25 Mar 2025AY 2005-06

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Waghe Prasadrao, Sr.DR
Section 115JSection 43(1)

cost of fixed assets, its impact on depreciation computation under Section 43(1) of the Act, and its implications for the determination of book profits under Section 115JB. 2.9. Following appeals have now been reconstructed and listed for adjudication - ITA No. Assessment Appellant Amount in Year Dispute (Rs.) 784/Ahd/2013 ... each other. 1. The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in recomputing the book profit u/s. 115JB of the Act. 2. The learned CIT(A) erred in fact and in law in holding that the amount of sales

The DCIT, Circle-4(1), Vadodara vs. Munjal Auto Industries Ltd., Vadodara

Appeal is dismissed

ITA 2007/AHD/2007[2004-05]Status: DisposedITAT Ahmedabad25 Mar 2025AY 2004-05

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Waghe Prasadrao, Sr.DR
Section 115JSection 43(1)

cost of fixed assets, its impact on depreciation computation under Section 43(1) of the Act, and its implications for the determination of book profits under Section 115JB. 2. 9. Following appeals have now been reconstructed and listed for adjudication - ITA No. Assessment Year Appellant Amount in Dispute (Rs.) 784/Ahd/2013 ... each other. 1. The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in recomputing the book profit u/s.115JB of the Act. 2. The learned CIT(A) erred in fact and in law in holding that the amount of sales tax subsidy

Strides Pharma Science Limited, Mumbai vs. Income Tax Officer, 15(3)(2), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 5721/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Mar 2025AY 2020-21

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सं./Ita No.5721/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) Strides Pharma Science Limited V/S. Ito 15(3)(2), बनाम Aayakar Bhavan, New 201, Devavrata, Sector-17, Marine Lines, Mumbai-400020 Vashi, Navi Mumbai, Maharashtra-400703 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Blrs03808A .. Appellant/अपीलार्थी Respondent/प्रतिवादी निर्धारिती की ओर से /Assessee By: Shri Nishit Gandhi राजस्व की ओर से /Revenue By: Mr. R. A. Dhyani सुनवाई की तारीख / Date Of Hearing 16.01.2025 20.03.2025 घोषणा की तारीख/Date Of Pronouncement आदेश / Order Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Dated 06.09.2024 Passed U/S.250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For

For Appellant: Shri Nishit GandhiFor Respondent: Mr. R. A. Dhyani
Section 143(3)Section 144Section 14ASection 250Section 35Section 37(1)

disallowance under section 14A of the Act. Ground 5: Disallowance/ Add back u/s 14A amounting to INR 1,73,37,851 to the Book Profits under MAT provisions 5.1 The learned AO and CIT(A) has erred in adding back the adjustments amounting to INR 1,73,37,851 which ... Appellants own case for the AY 2014-15 and other years wherein the AO was directed to delete the addition made to book profit computed under section 115JB of the Act on account of disallowance computed under section 14A of the Act. 5.4 The learned

ITO-26(2)(1), Mumbai vs. S D N Company, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2457/MUM/2024[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Bleι.Τ.Α. No. 2457/Mum/2024

For Appellant: Shri Firoze Andhiyarujina, Sr. Advocate & ManeckFor Respondent: Shri Dr. Kishor Dhule, CIT D/R
Section 14Section 56Section 56(2)(viia)

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 आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL Ι.Τ.Α. No. 2457/Mum/2024 7 thereto; (v) any amount representing provisions made

Deputy Commissinoer of Income Tax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

ITA 470/CHNY/2024[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca Department By Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement 19.03.2025

Section 115JSection 14ASection 2Section 37(1)

Ld.CIT(A) dated 29.12.2023 which is taken as the lead case for all the aforesaid assessment years [as well as issue in respect of book- profit u/s.115JB of the Act post amendment AY 2012-13] and the decision of which will be followed mutatis mutandis for the issues permeating ... Cholamandalam MS - General Insurance Co. Ltd. :: 4 :: provision of section 115JB do not allow any specific exemption for computation and taxation of book profits to insurance companies. 10. The appellant craves leave to add or amend any ground of appeal before it is finally disposed off. Ground No.1 is general

Deputy Commissioner of Incometax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

In the result, appeal filed by the assessee for AY 2011-12 is allowed

ITA 1489/CHNY/2024[2011-12]Status: DisposedITAT Chennai19 Mar 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Sandeep BagmarFor Respondent: Mr. Nilay
Section 115J

applicable to insurance companies without appreciating that the provision of section 115JB do not allow any specific exemption for computation and taxation of book profits to insurance companies. 5. For these and other grounds that may be urged at the time of hearing, it is prayed that the order ... reserve for unexpired risk payable to IMTPIP and re-assessed business income at Rs.87,91,42,980/- under normal provisions and re-assessed book profit by adding provision for IBNR/IBNER to the tune of Rs.8,78,92,000/- and re-assessed book profit at Rs.19,23,80,807/- by passing