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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

Addl CIT RG 1(1), Mumbai vs. Hdfc Ltd, Mumbai

ITA 3785/MUM/2009[2004-05]Status: DisposedITAT Mumbai28 Jan 2025AY 2004-05

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

debts would otherwise qualify as long-term finance for development of housing in India. II. Disallowance u/s. 14A of the Act. III. Increasing the book profits computed u/s. 115JB by the amount disallowed u/s. 14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation ... pricing adjustment in respect of specified domestic transactions (SDT) covered by section 40A(2)(b). XVIII. Disallowance of year-end provisions. XIX. Increasing the book profit computed u/s. 115JB by the amount disallowed as year-end provisions. XX. Deduction in respect of expenditure incurred on Employee Stock Option Scheme ('ESOS

Hdfc Bank Limited (As Successor to Housing Development Finance Corporation Ltd), Mumbai vs. The Addl CIT RG 1(1), Mumbai

ITA 4315/MUM/2007[2002-2003]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-2003

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

underlying debts would otherwise qualify as long-term finance for development of housing in India. II. Disallowance u/s.14A of the Act. III. Increasing the book profits computed u/s.115JB by the amount disallowed u/s.14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount ... pricing adjustment in respect of specified domestic transactions (SDT) covered by section 40A(2)(b). XVIII. Disallowance of year-end provisions. XIX. Increasing the book profit computed u/s.115JB by the amount disallowed as year-end provisions. XX. Deduction in respect of expenditure incurred on Employee Stock Option Scheme ('ESOS

DCIT Cir 1(1), Mumbai vs. M/S Housing Developement Finance Corporation Ltd, Mumbai

ITA 4162/MUM/2007[2003-2004]Status: DisposedITAT Mumbai28 Jan 2025AY 2003-2004

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocat
Section 1

underlying debts would otherwise qualify as long-term finance for development of housing in India. II. Disallowance u/s.14A of the Act. III. Increasing the book profits computed u/s.115JB by the amount disallowed u/s.14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount ... pricing adjustment in respect of specified domestic transactions (SDT) covered by section 40A(2)(b). XVIII. Disallowance of year-end provisions. XIX. Increasing the book profit computed u/s.115JB by the amount disallowed as year-end provisions. XX. Deduction in respect of expenditure incurred on Employee Stock Option Scheme ('ESOS

DCIT Cir 1(1), Mumbai vs. M/S Housing Developement Finance Corporation Ltd, Mumbai

In the result, appeals of both, assessee and revenue are decided

ITA 4161/MUM/2007[2002-2003]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-2003

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and
Section 1

underlying debts would otherwise qualify as long-term finance for development of housing in India. II. Disallowance u/s.14A of the Act. III. Increasing the book profits computed u/s.115JB by the amount disallowed u/s.14A of the Act. IV. Discount on grant of stock options (ESOP/ESOS) to employees. V. Computation of amount ... pricing adjustment in respect of specified domestic transactions (SDT) covered by section 40A(2)(b). XVIII. Disallowance of year-end provisions. XIX. Increasing the book profit computed u/s.115JB by the amount disallowed as year-end provisions. XX. Deduction in respect of expenditure incurred on Employee Stock Option Scheme ('ESOS

Excelra Knowledge Solutions Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

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

ITA 202/HYD/2023[2020-21]Status: DisposedITAT Hyderabad23 Jan 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.202/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Excelra Knowledge Vs. Dy. Cit Solutions (P) Ltd, Circle 8(1) Hyderabad Hyderabad Pan:Aafcg5715Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 25/11/2024 घोषणा की तारीख/Pronouncement: 23/01/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated10/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds:

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 10ASection 143(1)Section 438Section 43B

error or illegality in the impugned order of the learned CIT (A) qua this issue. 15. Ground No.3 is regarding wrong computation of book profit u/s 115JB of the I.T. Act, 1961. The learned AR of the assessee has submitted that the assessee has declared MAT at Rs.28 ... whereas the Assessing Officer has computed the book profit at Rs.35,32,40,420/-. The learned AR has referred to the computation of book profit u/s 115JB placed at Page No.105 as well as the profit and loss account placed at page No.117 of the paper book and submitted that

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Shri. Balaji Ramchandra Ande, Latur

In the result, appeal of the Revenue dismissed

ITA 625/PUN/2024[2018-19]Status: DisposedITAT Pune21 Jan 2025AY 2018-19

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Sharad A Shah And Shri Rohit S TapadiyaFor Respondent: Shri Ramnath P Murkunde
Section 115BSection 131Section 133ASection 143(2)Section 68Section 69ASection 69BSection 69C

opinion that the excess income declared should be assessed under the head "Income from other sources" which does not qualify for book profits as defined under the provisions of Sec.40(b) of the Act for the purpose of computing the quantum of allowable remuneration to the partners. The Assessing Officer

Holiday Triangle Travel Private Limited, Gurgaon vs. Income Tax Officer, Jaipur

In the result, appeal of the assessee is allowed

ITA 67/JPR/2024[2014-15]Status: DisposedITAT Jaipur20 Jan 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Dilip Shivpuri, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 142(1)Section 143(2)Section 250Section 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; any amount representing provisions made for (v) meeting liabilities, other than ascertained liabilities; 20 Holiday Triangle Travel

ACIT-3(4), Mumbai vs. Union Bank of India ( Erstwhile Corporation Bank), Mumbai

In the result both the appeals filed by the revenue are partly allowed

ITA 1228/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 Jan 2025AY 2020-21

Bench: Shri.B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Ananthan S / Ms. LalithaFor Respondent: ShriAshish Heliwal, CIT DR
Section 115JSection 143(3)Section 14ASection 250Section 251(1)(a)Section 36Section 36(1)(iii)Section 36(1)(vii)Section 36(1)(viia)

erred in deleting a sum of Rs. 4,27,73,538/- towards disallowance u/s 14A in computing the book profit u/s 115 JB of the Act?" (xii) "Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in allowing the claim ... rejected. 13. The issues raised in Ground Nos. (ix), (x), (xi), and (xii), which pertain to the applicability of Section 115JB, the addition to book profits by invoking Section 14A of the Act, and the allowability of education cess, are consequential in nature. Therefore, these grounds do not require separate

Deputy Commissioner of Income Tax, Circle-2(1)(1), Bengaluru vs. Canara Bank, Bengaluru

In the result, appeal of the revenue in ITA No

ITA 297/BANG/2024[2018-19]Status: DisposedITAT Bangalore17 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

For Appellant: Sri Abharana &Anantham, A.RsFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 143(3)Section 14ASection 234BSection 250

assessee u/s 115JB of the Act by adding various items not covered by the Explanation to section 115JB(2) of the Act and determined book profit of Rs.1605,72,87,823/- and tax liability of Rs.342,68,82,138/-. The ld. AO has raised a demand of Rs.1086 ... assessee bank is an Indian company for the purposes of I.T. Act, 1961 and therefore liable to pay Minimum Alternate Tax on the book profits, as per the provisions of section 115JB of the Act, for the year under consideration. Accordingly, ld. CIT(A) dismissed the ground of appeal

Deputy Commissioner of Income Tax, Circle-2(1)(1), Bengaluru vs. Canara Bank, Bengaluru

ITA 222/BANG/2024[2017-18]Status: DisposedITAT Bangalore17 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri Abrarana &Anantham, A.Rs
Section 115JSection 14ASection 250Section 36(1)

under the said provisions. 5. Without prejudice to the above, the learned CIT(A) erred in not deleting the various additions made to the Book Profits computed u/s 115JB. 5. 1. The learned CIT(A) erred in remanding the matter to the learned Assessing Officer to pass a speaking order ... assessee u/s 115JB of the Act by adding various items not covered by the Explanation to section 115JB(2) of the Act and determined book profit of Rs.1605,72,87,823/- and tax liability of Rs.342,68,82,138/-. The ld. AO has raised a demand of Rs.1086

Canara Bank, Bengaluru vs. The Deputy Commissioner of Income Tax, Circle 2(1)(1), Bangalore, Bengaluru

ITA 210/BANG/2024[2017-18]Status: DisposedITAT Bangalore17 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri Abrarana &Anantham, A.Rs
Section 115JSection 14ASection 250Section 38(1)(vii)

investment by the bank. 4. Without prejudice to the above, the learned CIT(A) erred in not deleting the various additions made to the book profits computed u/s 115JB. 4. 1. The learned CIT(A) failed to appreciate that the provisions of Section 115JB of the Act are not applicable

Canara Bank, Bengaluru vs. The Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore, Bengaluru

ITA 1154/BANG/2023[2018-19]Status: DisposedITAT Bangalore17 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Abarana &Anantham, A.RsFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 14ASection 250Section 38(1)

under the said provisions. 5. Without prejudice to the above, the learned CIT(A) erred in not deleting the various additions made to the book profits computed u/s 115JB. 5. 1. The learned CIT(A) erred in remanding the matter to the learned Assessing Officer to pass a speaking order ... assessee u/s 115JB of the Act by adding various items not covered by the Explanation to section 115JB(2) of the Act and determined book profit of Rs.1605,72,87,823/- and tax liability of Rs.342,68,82,138/-. The ld. AO has raised a demand of Rs.1086

The Vardhman Stampings Pvt. Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circle-4(1)(2), Ahmedabad

ITA 363/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumar

Section 263Section 43(5)Section 73

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'A' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

The Vardhman Stampings Pvt. Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circle-4(1)(2), Ahmedabad

ITA 362/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumar

For Appellant: Shri Manish J. Shah andFor Respondent: Shri H. Phani Raju, CIT-DR
Section 263Section 43(5)Section 73

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'A' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT

Dy. Commissioner of Income Tax, Circle-1(1), Pune vs. Bank of Maharashtra, Pune

ITA 428/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

learned CIT(A) failed to appreciate the fact that even if the provisions of section 115JB are applicable, the computation fails and as such, book profit cannot be computed as per section 115JB. 6. Without prejudice to Ground No. 5, the learned CIT(A) erred in confirming the addition ... various items to the book profit which are beyond the scope of the Section 115JB. 6. 1. The learned CIT(A) failed to appreciate the fact that the various items added to the book profit are not covered by the Explanation to Section 115JB. 7. The order of the learned

Bank of Maharashtra, Pune vs. Asst Commissioner of Income Tax, Circle 1(1), Pune

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

ITA 259/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

For Appellant: Shri S Ananthan & Smt. Abarna CAFor Respondent: Shri Amol Khairnar CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

learned CIT(A) failed to appreciate the fact that even if the provisions of section 115JB are applicable, the computation fails and as such, book profit cannot be computed as per section 115JB. 6. Without prejudice to Ground No. 5, the learned CIT(A) erred in confirming the addition ... various items to the book profit which are beyond the scope of the Section 115JB. 6.1. The learned CIT(A) failed to appreciate the fact that the various items added to the book profit are not covered by the Explanation to Section 115JB. 7. The order of the learned

The Lakshmi Mills Company Limited, Coimbatore vs. ACIT Corporate Circle - 2, Coimbatore

The appeal stand partly allowed in terms of our above order

ITA 364/CHNY/2024[2014-15]Status: DisposedITAT Chennai15 Jan 2025AY 2014-15

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.364/Chny/2024 (िनधा*रण वष* / Assessment Year: 2014-15) The Lakshmi Mills Company Ltd. Acit बनाम/ 686, Avanashi Road, Corporate Circle-2, Vs. Coimbatore -641 037. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaact-7564-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri T. Banusekar (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 31-12-2024 घोषणाकीतारीख /Date Of Pronouncement : 15-01-2025 आदेश / O R D E R

For Appellant: Shri T. Banusekar (Advocate) – Ld. ARFor Respondent: Shri Nilay Baran Som (CIT) -Ld. DR
Section 115JSection 143(3)

repairs for modernization expenses for Rs.296.46 Lacs; (iii) Disallowance of Prior period electricity charges for Rs.82.85 Lacs under normal provision and while computing Book Profit; (iv) Inadmissible expenses for Rs.14.60 Lacs; (v) Inadmissible expenses for Rs.18.91 Lacs. 2. The Ld. AR advanced arguments and referred to various documents to support ... adjudication. The corresponding grounds stand allowed for statistical purposes. 5. Disallowance of Prior period electricity charges under normal provisions as well as while computing book profits 5.1 Based on audit objections of TNEB, a demand of Rs.185.42 Lacs was raised which pertained to periods from 2011 to 2013. The assessee

DCIT-1(2)1, Mumbai. vs. Patil Construction and Infrastructure Ltd, Mumbai

In the result, all the three appeals filed by the revenue

ITA 4944/MUM/2024[2017-18]Status: DisposedITAT Mumbai14 Jan 2025AY 2017-18

Bench: Shri Sandeep Gosain, Hon'Ble & Ms. Padmavathy S., Hon'Bleι.Τ.Α. No.4940/Mum/2024

For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

issues relating to the allowability of the deduction under Section 801A (i) first time claimed in the returns filed under Section 153A on the book-profits and (ii) claimed in the returns filed under Section 153A on the additional income computed with reference to the seized papers. He dealt ... course of hearing on 23.02.2015, the department first reiterated its stand that the deduction cannot be allowed either in respect of the book profits or the in the case of Charchit Agrawal vs ACIT (129 TTJ438) and Home Tex Vs. CIT(2012) 20 Тахтап.com 729 were filed and elaborated

DCIT-1(2)1, Mumbai. vs. Patil Construction and Infrastructure Ltd, Mumbai

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

ITA 4942/MUM/2024[2015-16]Status: DisposedITAT Mumbai14 Jan 2025AY 2015-16

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

time claimed in the returns filed under Section first time claimed in the returns filed under Section 153A on the book 153A on the book-profits and (ii) claimed in the returns filed profits and (ii) claimed in the returns filed under Section 153A on the additional income computed with ... that the deduction cannot be allowed first reiterated its stand that the deduction cannot be allowed either in respect r in respect of the book profits or the in the case of of the book profits or the in the case of Charchit Agrawal vs ACIT (129 TTJ438) and Home

DCIT-1(2)1, Mumbai vs. Patil Construction and Infrastructure Ltd, Mumbai

In the result In the result, all the three appeals filed by the revenue s filed by the revenue are dismissed

ITA 4940/MUM/2024[2014-15]Status: DisposedITAT Mumbai14 Jan 2025AY 2014-15

Bench: Shri Sandeep Gosain, Hon’Ble & Ms. Padmavathy S., Hon’Ble

For Appellant: Mandar VaidyaFor Respondent: Shri Krishna Kumar, Sr. D/R
Section 801A

time claimed in the returns filed under Section first time claimed in the returns filed under Section 153A on the book 153A on the book-profits and (ii) claimed in the returns filed profits and (ii) claimed in the returns filed under Section 153A on the additional income computed with ... that the deduction cannot be allowed first reiterated its stand that the deduction cannot be allowed either in respect r in respect of the book profits or the in the case of of the book profits or the in the case of Charchit Agrawal vs ACIT (129 TTJ438) and Home