← All Phrases

“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

Viiking Media and Entertainment Pvt. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 2(2), Mumbai

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

ITA 6034/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Feb 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Girish Agarwal, Am Viiking Media & Entertainment Deputy Commissioner Of Income Pvt. Ltd. Tax, Central Circle 2(2), Mumbai 604-605, 6Th Floor, Gateway Plaza, 604-605, 6Th Floor, Gateway Plaza, Vs. Central Circle 2(2), Mumbai – 400076. Central Circle 2(2), Mumbai – 400076. Pan/Gir No. Aaacj9884E (Assessee) : (Respondent) Assessee By : Shri. Aakash Kumar Respondent By : Shri. Ajay Singh, Sr Dr Date Of Hearing : 06.02.2025 Date Of Pronouncement : 07.02.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Ex Parte Order Of The Learned Commissioner Of Income Tax (Appeals) 52, Mumbai (‘Ld. Cit(A) For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2017-18. 2. It Is Observed That The Present Appeal Has Been Filed With A Delay Of 16 Days For Which The Accountant Of The Ld.Ar Appearing For The Assessee Has Filed Application Dated 06.02.2025 Along With An Affidavit For Condoning The Said Delay. Upon Perusal Of The Same, We Deem It Fit To Hold That The Assessee Had “Sufficient Cause” For The Said Delay M/S. Viiking Media & Entertainment Pvt. Ltd. & Therefore We Are Inclined To Condone The Delay Caused By The Assessee In Filing The Present Appeal. Delay Condoned.

For Appellant: Shri. Aakash KumarFor Respondent: Shri. Ajay Singh, SR DR
Section 115JSection 143(2)Section 143(3)Section 250Section 36(1)(va)Section 68

determining total income at Rs. 4,24,50,400/-, under the normal provision and Rs. 3,13,51,790/- u/s. 115JB on the book profits after making addition/disallowance u/s. 68 and 36(1)(va) of the Act. 5. Aggrieved the assessee was in appeal before the first appellate authority, challenging

Income Tax Officer, Corporate Ward 3(3), Chennai, Wanaparthy Block, Income Tax Office vs. Woosu Automotive India P Limited, Tiruvallur

The appeal stand allowed for statistical purposes

ITA 2117/CHNY/2024[2017-18]Status: DisposedITAT Chennai03 Feb 2025AY 2017-18

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2117/Chny/2024 (िनधा*रण वष* / Assessment Year: 2017-18) Income Tax Officer M/S. Woosu Automotive Pvt. Ltd. बनाम/ Corporate Ward-3(3), #130, Narasingapuram Village, Vs. Wanaparthy Block, Chennai. Perampakkam Post, Thiruvallur-631 402. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaacw-7285-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Nilay Baran Som (Cit)-Ld. Dr ""थ"कीओरसे/Respondent By : Shri Shreyansh Kumar Kochar (Ca) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 21-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 03-02-2025 आदेश / O R D E R

For Appellant: Shri Nilay Baran Som (CIT)-Ld. DRFor Respondent: Shri Shreyansh Kumar Kochar (CA) - Ld. AR
Section 115JSection 143(3)Section 154Section 2

erred in deleting the adjustment made by the Assessing Officer on account of refund of Excise duty while computing book profits u/s.115JB of the Act of Rs.5,49,64,786. 3. The ld. CIT(A) erred in accepting the contention of the assessee that profit and loss account was prepared ... 115JB of the Act. 2. As is evident, the sole issue that arises for our consideration is adjustment of excise duty refund while computing book profits u/s 115JB. Having heard rival submissions, the appeal is disposed-off as under. 3. From the facts, it emerges that an assessment was framed