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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, Circle 10, New Delhi vs. Indus Tower Limited, Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 2212/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

after giving due effect to the aforesaid merger, reporting a loss of (Rs.793,20,41,502/-) under normal provisions of the Act and a book profit of Rs.4,69,90,41,333/- as per the provisions of section 115JB of the Act. The aforesaid revised return of income was treated ... raised by the assessee are challenging the upward adjustment of depreciation on aforesaid assets obtained pursuant to the scheme of arrangement, while computing book profits under section 115JB of the Act. 3.32 We have heard the rival submissions and perused the materials available on record. The Passive Infrastructure Assets (PIAs

Indus Towers Ltd., Gurgaon vs. DCIT Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1962/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR
Section 115JSection 139(5)Section 142Section 143(3)Section 148

after giving due effect to the aforesaid merger, reporting a loss of (Rs.793,20,41,502/-) under normal provisions of the Act and a book profit of Rs.4,69,90,41,333/- as per the provisions of section 115JB of the Act. The aforesaid revised return of income was treated ... raised by the assessee are challenging the upward adjustment of depreciation on aforesaid assets obtained pursuant to the scheme of arrangement, while computing book profits under section 115JB of the Act. 3.32 We have heard the rival submissions and perused the materials available on record. The Passive Infrastructure Assets (PIAs

M/S. Trivitron Healthcare Pvt. Ltd., Chennai vs. PCIT, Chennai-3

In the result, the appeal filed by the assessee is partly

ITA 1745/CHNY/2024[2018-19]Status: DisposedITAT Chennai05 Dec 2024AY 2018-19
For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. M. Murali, CIT
Section 115JSection 143(3)Section 263Section 35

order passed u/s.143(3) by the AO with a direction to verify the record with regard to loss or unabsorbed depreciation and compute the book profit u/s.115JB accordingly. 4. Briefly stated facts are that the assessee company filed its return of income ... noticed that the assessee had deducted an amount of Rs.4,47,55,031/- towards Brought forward loss or Unabsorbed depreciation and arrived at a Book Profit of Rs.1,49,70,530/-. 4.1 For the purpose of MAT 'book profit' means the net profit as shown in the P&L account

Bse Limited, Fort, Mumbai vs. DCIT Circle 2(1)(1), Aaykar Bhavan

In the result, assessee’s appeal ITA No

ITA 2662/MUM/2024[2018-19]Status: DisposedITAT Mumbai02 Dec 2024AY 2018-19

Bench: SMT MS. PADMAVATHY S (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 115JSection 143(2)Section 14ASection 201Section 250Section 37(1)

worked out under rule 8D of the IT Rules 1962 but rejected assessee’s plea of adjustments of the amount u/s. 14A while calculating book profit u/s. 115JB of the Act, but for statistical purposes. However, learned CIT(A) deleted the disallowance of set aside amount ... failed to consider Ground no 5 "Without prejudice to the above, Adjustments of expenses of Rs. 17,83,25,426/- u/s 14A while calculating book profit u/s 115]B of the Income Tax Act, 1961." 3) The Learned CIT(A), NFAC erred in directing the assessing officer to recalculate

ACIT-2(1)(1), Mumbai vs. Bse Ltd, Mumbai

In the result, assessee’s appeal ITA No

ITA 2440/MUM/2024[2018-19]Status: DisposedITAT Mumbai02 Dec 2024AY 2018-19

Bench: SMT MS. PADMAVATHY S (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 115JSection 143(2)Section 14ASection 201Section 250Section 37(1)

worked out under rule 8D of the IT Rules 1962 but rejected assessee’s plea of adjustments of the amount u/s. 14A while calculating book profit u/s. 115JB of the Act, but for statistical purposes. However, learned CIT(A) deleted the disallowance of set aside amount ... failed to consider Ground no 5 "Without prejudice to the above, Adjustments of expenses of Rs. 17,83,25,426/- u/s 14A while calculating book profit u/s 115]B of the Income Tax Act, 1961." 3) The Learned CIT(A), NFAC erred in directing the assessing officer to recalculate

Bank of India, Mumbai vs. The Deputy Commissioner of Income Tax-2(1)(2), Mumbai

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

ITA 928/MUM/2023[2016-2017]Status: DisposedITAT Mumbai29 Nov 2024AY 2016-2017

Bench: Smt. Beena Pillai

For Respondent: Shri Kailash C. Kanojiya
Section 115JSection 143(3)Section 263Section 438Section 43B

under the normal provisions. Also, various additions aggregating to Rs. 11973,94,22,456/- were made while determining book profit u/s 115JB at Rs. 3867,43,63,858/-. Page |3 ITA No. 928/Mum/2023 ALY. 2017-18 Bank of India 4. Ld. CIT(A) passed an order allowing part relief ... Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 and therefore, the provision of Section 115JB cannot be applied and consequently, the tax on book profits (MAT) are not applicable to such banks.” 12. Since the assessee is also covered by the notification regarding “corresponding new bank” in terms

Millennium Appliances India Ltd, Mumbai vs. ITO RG 3(2)(4), Mumbai

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

ITA 3289/MUM/2013[2009-10]Status: DisposedITAT Mumbai29 Nov 2024AY 2009-10

Bench: Smt. Beena Pillai & Smt. Renu Jauhrim/S. Millennium V/S. Ito, Range 3(2)(4), Appliances India Ltd. बनाम Mumbai 171-C, Mittal Court, Aayakar Bhavan, Nariman Point, Mumbai-400020 Mumbai-400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccm7838D Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Madhur Agarwal &For Respondent: Shri Kailash C. Kanojiya
Section 115JSection 143(1)Section 143(3)Section 14ASection 14A(2)Section 250

Rs.1,13,63,071/- being the amount disallowed by invoking the provisions of Section 14A read with rule 8D, to the book profit for the purpose of Section 115JB of the Income Tax Act, 1961 which is wrong and contrary to the provisions of the Income ... Income Tax (Appeals) erred in confirming the addition of Rs.14,43,877/- being the amount of provision for warranty and maintenance expenses to the book profit for the purpose of Section 115JB of the Income Tax Act, 1961, by treating the said provision as unascertained liability, and the reasons assigned

Bank of Baroda ( Erstwhile Vijaya Bank), Mumbai vs. Joint Commissioner of Income Tax, Ltu, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 1040/BANG/2024[2017-18]Status: DisposedITAT Bangalore28 Nov 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Smt. Lalitha Rameswaran, CA &For Respondent: Shri Sridhar .E, CIT-DR
Section 115JSection 135Section 37

facts of the case are that the assessee is a nationalized bank and during the A.Y. 2014-15, the assessee had not computed the book profit u/s. 115JB of the Act on the ground that the assessee is not a company but Page ... 1040/Bang/2024 only a public sector bank. The AO computed the book profit u/s. 115JB of the Act and also made certain disallowances while computing the book profits and added the same to the book profits arrived u/s. 115JB of the Act. The assessee challenged the said proceedings before the Ld.CIT

Bank of Baroda, Mumbai vs. Joint Commissioner of Income Tax, Ltu, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 1033/BANG/2024[2016-17]Status: DisposedITAT Bangalore28 Nov 2024AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Smt. Lalitha Rameswaran, CA &For Respondent: Shri Sridhar .E, CIT-DR
Section 115JSection 135Section 37

facts of the case are that the assessee is a nationalized bank and during the A.Y. 2014-15, the assessee had not computed the book profit u/s. 115JB of the Act on the ground that the assessee is not a company but Page ... 1040/Bang/2024 only a public sector bank. The AO computed the book profit u/s. 115JB of the Act and also made certain disallowances while computing the book profits and added the same to the book profits arrived u/s. 115JB of the Act. The assessee challenged the said proceedings before the Ld.CIT

Bank of Baroda, Mumbai vs. Joint Commissioner of Income Tax, Ltu, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 1032/BANG/2024[2014-15]Status: DisposedITAT Bangalore28 Nov 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Smt. Lalitha Rameswaran, CA &For Respondent: Shri Sridhar .E, CIT-DR
Section 115JSection 135Section 37

facts of the case are that the assessee is a nationalized bank and during the A.Y. 2014-15, the assessee had not computed the book profit u/s. 115JB of the Act on the ground that the assessee is not a company but Page ... 1040/Bang/2024 only a public sector bank. The AO computed the book profit u/s. 115JB of the Act and also made certain disallowances while computing the book profits and added the same to the book profits arrived u/s. 115JB of the Act. The assessee challenged the said proceedings before the Ld.CIT

M.P.Recycling Company Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2)(1), Mumbai

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

ITA 4205/MUM/2024[2015-16]Status: FixedITAT Mumbai27 Nov 2024AY 2015-16

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M. P. Recycling Company Private Asst. Cit, Central Circle 4(2)(1) Mumbai-400 020 Limited Vs. 51-53/A, Mittal Court, Nariman Point, Mumbai-400 021 Pan/Gir No. Aadcm 3153 A (Assessee) : (Respondent) Assessee By : None : Shri R. R. Makwana Respondent By : 17.10.2024 Date Of Hearing Date Of Pronouncement : 27.11.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) (‘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) 2015-16. 2. As There Was No Representation On Behalf Of The Assessee, We Hereby Dispose Of This Appeal By Hearing The Learned Departmental Representative ('Ld.Dr' For Short) & On Perusal Of The Materials Available On Record. 3. The Assessee Has Raised The Following Grounds Of Appeal: “The Commissioner Of Income-Tax (Appeals) At The National Faceless Appeal Centre (Nfac) (Hereinafter Referred To As The Cit(A)) Erred In Upholding The Action Of The Assistant Commissioner Of Income-Tax, Circle 4(2)(1), Mumbai (Hereinafter Referred To As The Assessing Officer) In Levying The Impugned Penalty Of Rs 2,65,12,070 Under Section 271(1)(C) Of The Act.

For Appellant: NoneFor Respondent: 17.10.2024
Section 143(1)Section 250Section 271(1)(c)Section 274

determining total income at Rs. 4,60,20,220/- under the normal provisions and Rs. 3,51,36,024/- on book profits after making various addition/disallowance. The ld. AO also initiated penalty proceedings u/s. 271(1)(c) of the Act for concealment of particulars of income. The ld. AO vide

Astra Zeneca Pharma India Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 419/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Nov 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayana, CAFor Respondent: Ms. Neera Malhotra, CIT (DR)

next issue raised by the assessee in ground No. 21 is that the ld. DRP is erred in making the adjustment to the book profit of Rs. 54,25,13,912/- under section 115JB of the Act. 12. The AO in the draft assessment order has added the transfer pricing ... other corporate disallowance made by the AO . IT(TP)A Nos.419 & 876/Bang/2022 Page 6 of 10 under normal computation of income to the book profit computed u/s 115JB of the Act. On being objection raised by the assessee, the ld. DRP, confirmed such adjustment made by the AO by observing

Dow Chemical International Private Limited, Thane vs. Deputy Commissioner of Income Tax - 14(1)(2), Mumbai

ITA 3772/MUM/2023[2016-17]Status: DisposedITAT Mumbai25 Nov 2024AY 2016-17

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Rajan VoraFor Respondent: Ms. Rajeshwari Menon, Sr. AR /
Section 142(1)Section 143(2)Section 143(3)Section 250Section 32

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

Dow Chemicals International Private Limited, Mumbai vs. Deputy Commissioner of Income Ta-14(1)(2), Mumbai

ITA 1200/MUM/2023[2018-2019]Status: DisposedITAT Mumbai25 Nov 2024AY 2018-2019

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Rajan VoraFor Respondent: Ms. Rajeshwari Menon, Sr. AR /
Section 142(1)Section 143(2)Section 143(3)Section 250Section 32

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

JCIT(OSD) Corporate Circle-1(1), Chennai vs. Indian Bank, Chennai

ITA 527/CHNY/2023[2018-19]Status: DisposedITAT Chennai20 Nov 2024AY 2018-19
Section 250Section 36(1)(vii)Section 36(1)(viia)

115JB is fulfilled in the present case of the assessees. Sub-section (1) of Section 115JB mandates charge of income tax based on book profits subject to fulfillment of certain conditions and also provides the rate on which such tax shall be charged. The Section starts with non-obstante clause ... charge of tax on the total income of the company. Sub-section (2) is the computation provision dealing with the manner in which such book profits are to be computed. Upto A.Y.2012-13, sub-section (2) of Section 115JB applied only to such companies which were required to prepare its profit

JCIT(OSD) Corporate Circle-1(1), Chennai vs. Indian Bank, Chennai

ITA 526/CHNY/2023[2017-18]Status: DisposedITAT Chennai20 Nov 2024AY 2017-18
Section 250Section 36(1)(vii)Section 36(1)(viia)

115JB is fulfilled in the present case of the assessees. Sub-section (1) of Section 115JB mandates charge of income tax based on book profits subject to fulfillment of certain conditions and also provides the rate on which such tax shall be charged. The Section starts with non-obstante clause ... charge of tax on the total income of the company. Sub-section (2) is the computation provision dealing with the manner in which such book profits are to be computed. Upto A.Y.2012-13, sub-section (2) of Section 115JB applied only to such companies which were required to prepare its profit

JCIT(OSD) Corporate Circle-1(1), Chennai vs. Indian Bank, Chennai

ITA 517/CHNY/2023[2016-17]Status: DisposedITAT Chennai20 Nov 2024AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shukla

Section 250Section 36(1)(vii)Section 36(1)(viia)

115JB is fulfilled in the present case of the assessees. Sub-section (1) of Section 115JB mandates charge of income tax based on book profits subject to fulfillment of certain conditions and also provides the rate on which such tax shall be charged. The Section starts with non-obstante clause ... charge of tax on the total income of the company. Sub-section (2) is the computation provision dealing with the manner in which such book profits are to be computed. Upto A.Y.2012-13, sub-section (2) of Section 115JB applied only to such companies which were required to prepare its profit

JCIT(OSD) Corporate Circle-1(1), Chennai vs. Indian Bank, Chennai

ITA 516/CHNY/2023[2015-16]Status: DisposedITAT Chennai20 Nov 2024AY 2015-16
For Appellant: Shri M.Sanjeev Aditya, C.AFor Respondent: Ms.Nayani Swapna, CIT
Section 250Section 36(1)(vii)Section 36(1)(viia)

fulfilled in the present case of the\r assessees. Sub-section (1) of Section 115JB mandates charge of income tax based\r on book profits subject to fulfillment of certain conditions and also provides the rate\r on which such tax shall be charged. The Section starts with non-obstante ... total income of the\r company. Sub-section (2) is the computation provision dealing with the manner in\r which such book profits are to be computed. Upto A.Y.2012-13, sub-section (2) of\r Section 115JB applied only to such companies which were required to prepare its\r profit

The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad vs. Suzlon Energy Ltd., Ahmedabad

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between tax on total income and tax on book profit. There is no deeming of total income ... 115JB, hence disallowance u/s. 14A cannot be applied while computing book profit. Further in opening line of first sub-section it has been clearly mentioned that the subject disallowance is to be made for the purpose of computing income under THIS CHAPTER only i.e. Chapter IV which relates to computation

The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad vs. Suzlon Energy Ltd., Ahmedabad

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between tax on total income and tax on book profit. There is no deeming of total income ... 115JB, hence disallowance u/s. 14A cannot be applied while computing book profit. Further in opening line of first sub-section it has been clearly mentioned that the subject disallowance is to be made for the purpose of computing income under THIS CHAPTER only i.e. Chapter IV which relates to computation