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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

The Deputy Commissioner of Income Tax, Circle-1, Udupi. vs. M/S Syndicate Bank, Udupi

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

ITA 337/PAN/2016[2002-03]Status: DisposedITAT Panaji09 Oct 2023AY 2002-03

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.337/Pan/2016 िनधा"रण वष" / Assessment Year : 2002-03 Dcit, Circle-1, Udupi. Vs. M/S. Syndicate Bank, Central Accounts Department, Tax Cell, Head Officer, Manipal. Pan : Aaccs4699E Appellant Respondent C.O. No.01/Pan/2023 (Arising Out Of Ita No.337/Pan/2016) िनधा"रण वष" / Assessment Year : 2002-03 Canara Bank (Erstwhile Vs. Dcit, Circle-1, Udupi. Syndicate Bank), F.M. Wing, Head Office, 112, J. C. Road, Bengaluru- 560002. Pan : Aaacc6106G Appellant Respondent Revenue By : Smt. Ashwini D. Hosmani Assessee By : Shri S. Ananthan Smt. S. Lalitha R. Date Of Hearing : 07.09.2023 Date Of Pronouncement : 09.10.2023

For Appellant: Shri S. AnanthanFor Respondent: Smt. Ashwini D. Hosmani
Section 115JSection 143(3)Section 14ASection 244A

Income for the assessment year 2002-03 was filed on 29.10.2002 declaring total income of Rs.1,31,027/- under the normal provisions of book profit of Rs.268,47,11,386/- u/s 115JB of the Income Tax Act, 1961 (‘the Act’). The assessment, against the said return of income, was completed ... giving effect to the order of the ITAT dated 16.03.2011 determining the total income under the normal provisions of Rs.123,64,06,123/- and book profits of Rs.375,04,01,900/- under the provisions of section 115JB of the Act. While doing so, the Assessing Officer made addition of Rs.98

M/S Terecom (P) Ltd., Goa vs. The Assistant Commissioner of Income Tax, Circle-2 (1), Panaji.

In the result, the appeal filed by the assessee stands dismissed

ITA 63/PAN/2017[2009-10]Status: DisposedITAT Panaji06 Oct 2023AY 2009-10

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Prabhakar Anand
Section 115JSection 143(3)Section 148

Return of Income for the 2 assessment year 2009-10 was filed on 30.09.2009 disclosing Rs.Nil income under the normal provisions of book profit of Rs.14,60,06,022/- u/s 115JB of the Income Tax Act, 1961 (‘the Act’). Against the said return of income, the assessment was completed ... Assessing Officer’) vide order dated 16.12.2011 passed u/s 143(3) of the Act at a total income of Rs.Nil under the normal provisions of book profits of Rs.14,60,06,022/- u/s 115JB of the Act. Subsequently, the assessment was reopened by issuing of notice

Strides Pharma Science Ltd., Navi Mumbai vs. The Dy CIT -5(1)(2), Mumbai

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

ITA 1004/MUM/2021[2016-17]Status: DisposedITAT Mumbai05 Oct 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

For Respondent: Ms Samruddhi Hande SR DR
Section 143(3)Section 14ASection 92C

without appreciating the fact that the investments were made during the current/past years out of its own funds/ internal accruals. 6 Re-computation of book profits under Section 115JB of the Act INR 15,34,55,236 [Page 4 to 8 of the Assessment Order] ITA NO. 1004/MUM/2021 ... Strides Pharma Science Ltd. 6.1 The Hon'ble DRP and the learned AO grossly erred in re- computing the book profit under Section 11518 of the Act by making addition of an amount of INR 15,34,55,236 towards expenditure incurred for earning exempt income under section

ACIT, Circle- 25(1), New Delhi vs. Tata Power Delhi Distribution Ltd. (Formely Known As North Delhi Power Ltd.), New Delhi

In the result, both the appeals of the assessee are partly allowed for statistical purposes and both the appeals of the revenue are dismissed

ITA 4454/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Oct 2023AY 2012-13

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Ms. Shashi M. Kapila, AdvFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT DR
Section 115JSection 143(3)Section 801A

normal provisions of the Act. (AO para 4 to 4.3/ CIT (A) para 8) (ii) That the Ld. CIT(Appeal) erred in increasing the book profits by the amount of Rs. 1,92,07,000 under section 115JB of the Act, being interest liability on additional security deposits of consumers ... raised is as under:- “That on the facts and in the circumstances of the case, the ld Assessing Officer erred in law in taxing book profits of Rs. 303.91 Crores under Section 115JB of the Act.” 5. We have heard the rival submissions and perused the materials available on record

ACIT, Circle- 25(1), New Delhi vs. Tata Power Delhi Distribution Ltd. (Formely Known As North Delhi Power Ltd.), New Delhi

In the result, both the appeals of the assessee are partly allowed for statistical purposes and both the appeals of the revenue are dismissed

ITA 4453/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Oct 2023AY 2011-12

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Ms. Shashi M. Kapila, AdvFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT DR
Section 115JSection 143(3)Section 801A

normal provisions of the Act. (AO para 4 to 4.3/ CIT (A) para 8) (ii) That the Ld. CIT(Appeal) erred in increasing the book profits by the amount of Rs. 1,92,07,000 under section 115JB of the Act, being interest liability on additional security deposits of consumers ... raised is as under:- “That on the facts and in the circumstances of the case, the ld Assessing Officer erred in law in taxing book profits of Rs. 303.91 Crores under Section 115JB of the Act.” 5. We have heard the rival submissions and perused the materials available on record

Tata Power Delhi Distribution Ltd., Delhi vs. DCIT, Circle-25(1), Delhi

In the result, both the appeals of the assessee are partly allowed for statistical purposes and both the appeals of the revenue are dismissed

ITA 4098/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Oct 2023AY 2012-13

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Ms. Shashi M. Kapila, AdvFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT DR
Section 115JSection 143(3)Section 801A

normal provisions of the Act. (AO para 4 to 4.3/ CIT (A) para 8) (ii) That the Ld. CIT(Appeal) erred in increasing the book profits by the amount of Rs. 1,92,07,000 under section 115JB of the Act, being interest liability on additional security deposits of consumers ... raised is as under:- “That on the facts and in the circumstances of the case, the ld Assessing Officer erred in law in taxing book profits of Rs. 303.91 Crores under Section 115JB of the Act.” 5. We have heard the rival submissions and perused the materials available on record

Tata Power Delhi Distribution Ltd., Delhi vs. DCIT, Circle-25(1), Delhi

In the result, both the appeals of the assessee are partly allowed for statistical purposes and both the appeals of the revenue are dismissed

ITA 4097/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Oct 2023AY 2011-12

Bench: Shri Kul Bharat & Shri M. Balaganesh

For Appellant: Ms. Shashi M. Kapila, AdvFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT DR
Section 115JSection 143(3)Section 801A

normal provisions of the Act. (AO para 4 to 4.3/ CIT (A) para 8) (ii) That the Ld. CIT(Appeal) erred in increasing the book profits by the amount of Rs. 1,92,07,000 under section 115JB of the Act, being interest liability on additional security deposits of consumers ... raised is as under:- “That on the facts and in the circumstances of the case, the ld Assessing Officer erred in law in taxing book profits of Rs. 303.91 Crores under Section 115JB of the Act.” 5. We have heard the rival submissions and perused the materials available on record

Idbi Bank Ltd., Mumbai vs. ACIT-Ltu(2), Mumbai

In the result, appeal of the revenue is dismissed

ITA 4596/MUM/2019[2016-17]Status: DisposedITAT Mumbai28 Sept 2023AY 2016-17

Bench: Shri Kuldip Singh & Shri Gagan Goyalidbi Bank Ltd. 22Nd Floor, Idbi Tower, Wtc Complex, Cuffe Parade, Mumbai- 400 005. Pan: Aabci8842G ..... Appellant Vs. Acit Ltu (2) World Trade Centre, Cuffe Parade, Mumbai ..... Respondent

For Appellant: NoneFor Respondent: None
Section 115JSection 143(1)Section 143(3)Section 14ASection 250Section 36(1)Section 36(2)Section 40

erred in not deciding on the specific ground raised by appellant on disallowance of provision made for expenses in computing book profits u/s. 115JB even when the same was allowed in computing income under normal provisions of the Act. IDBI Bank Ltd. Your appellant craves leave to add, to amend ... respectfully submitted that the amount of Rs. 5299 crore claimed by assessee should have been allowed as deduction. This issue in context of book profits was allowed by Hon'ble ITAT in appellants own case in A.Y. 2008-09 in ITA 3423/Mum/ 2018 where it was held that when provision

ACIT, Circle-7(1), New Delhi vs. Delhi State Industrial and Infrastructure Development Corporation Ltd., New Delhi

In the result, the captioned appeal of the Revenue is dismissed

ITA 7265/DEL/2019[2011-12]Status: DisposedITAT Delhi26 Sept 2023AY 2011-12

Bench: Sh. Pradip Kumar Kedia & Sh. Yogesh Kumar Usacit Vs. Delhi State Industrial & Circle – 7(1) Infrastructure Development New Delhi Corporation Ltd., N-36, Bombay Life Building, Connaught Circus, Pan No. Aaacd 1257 F New Delhi-110 001 (Appellant) (Respondent) Assessee By Shri Yogesh Jain & Shri Shobhit Kansal, C.A. Revenue By Shri Sanjay Kumar, Sr. D.R. Date Of Hearing: 27.06.2023 Date Of Pronouncement: 26.09.2023 Per Pradip Kumar Kedia, Am : The Captioned Appeal Has Been Filed By The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) – 2, New Delhi (‘Cit(A)’ In Short) Dated 28.06.2019 Arising From The Assessment Order Dated 28.11.2018 Passed By The Assessing Officer (Ao) Under Section 147/143(3)/263 Of The Income Tax Act, 1961 (The Act) Concerning Assessment Year 2011-12. 2. The Ground Of Appeal Raised By Assessee Reads As Under:

Section 115JSection 147Section 148

facts and in the circumstances of the case and in law, the Ld. CITA) has erred in deleting the addition to book profits of Rs.4,12,23,820/- on account of provision for Bad Debts.” 3. Briefly stated, the case of the assessee was re-opened under Section 148 read ... with Section 147 of the Act for the reason that‘book profits’declared by the assessee for the purpose of MAT provisions of Section 115JB was alleged to be under reported by making wrong claim towards provision for doubtful loans and advances/debts since ACIT vs. Delhi State Industrial and Infrastructure

M/S Abbas Shabuddin Saheb, Nipani vs. Income Tax Officer, Ward - 1, Nipani

In the result, the appeal filed by the assessee stands allowed

ITA 461/PAN/2018[2014-15]Status: DisposedITAT Panaji25 Sept 2023AY 2014-15

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri A. S. PatilFor Respondent: Smt. Ashwini Hosmani
Section 115BSection 131Section 133ASection 143(3)Section 40Section 69

Assessing Officer was of the opinion that the income disclosed during the course of survey proceedings does not qualify for the purpose of book profits to compute the eligible partner’s remuneration u/s 40(b)(v) of the Act. 3. Being aggrieved by the above order of assessment, an appeal ... subject to tax u/s 115BBE of the Act and also confirmed that the undisclosed income u/s 69 does not form part of the book profits for the purpose of computing the partner’s remuneration u/s 40(b)(v) of the Act. 4. Being aggrieved, the appellant is in appeal before

Assistant Commissioner of Income Tax (Central), Bilaspur vs. M/S Jagannathdas Harichandmal Jewellers Pvt. Ltd, Raigarh

In the result appeal of revenue is partly allowed in terms of our observations herein above

ITA 106/RPR/2022[2012-13]Status: DisposedITAT Raipur22 Sept 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.106/Rpr/2022 िनधा"रण वष" /Assessment Year: 2012-13 The Assistant Commissioner Of Vs M/S. Jagannathdas Harichandmal Income Tax (Central), Bilaspur Jewellers Pvt. Ltd. Sadar Bazar, Raigarh (C.G.) Pan: Aaccj2840G (अपीलाथ" /Appellant) (""यथ" / Respondent) .. िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agrawal, Ca राज"व क" ओर से /Revenue By : Shri Choudhary N.C. Roy, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 14/07/2023 घोषणा क" तार"ख/Date Of Pronouncement : 22/09/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Captioned Appeal Is Filed By The Revenue Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals)-3, Bhopal, Dated 16.03.2022 Which In Turn Arises From The Order By Ld. Assessing Officer U/S 143(3) R.W.S. 147 Dated 30.12.2018 For A.Y.2012-13. The Grounds Of The Appeal Raised By The Revenue Are As Under: “ 1. Whether On The Fact & In The Circumstances Of The Case In Law, While Holding Assessment Passed U/S 147 R.W.S. 143(3) Of Act As Invalid & Void-Ab-Initio, The Ld. Cit(A) Completely Ignored The Fact That During The Course Of Survey, The Assessee Failed To Discharge Its Burden In Establishing 'The Identity, Creditworthiness & Genuineness Of The Transactions As Required U/S 68 Of The Income Tac Act. Ld. Cit(A) Erred In Ignoring That Reassessment Proceeding Are Based On Fresh Facts/Information Rather Than Change Of Opinion. 2. Whether On The Fact & In The Circumstances Of The Case In Law, The Ld.Cit(A) Erred In Ignoring That Confirmation Of Concealment Of Income/Disclosure Made In Statement Recorded During Survey U/S 133A Of Act Is An Information, Though Not Conclusive, Which May Be Used In Regular Assessment Or Reassessment Proceedings.

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 133ASection 143(3)Section 147Section 148Section 68

Petitioner to show cause why the amount of Rs.47.04 crones being claimed as book depreciation on intangibles should not be disallowed to determine book profits under Section 115JB of the Act. The above query of the Assessing Officer was responded to by the Petitioner in great detail by its letters ... support of its contention that they are entitled to deduction of the current years depreciation from the net profit to arrive at the book profits under Section 115JB of the Act. It was also explained that under subsection 6 of Section 211 of the Companies Act, reference to a balance

DCIT-3(2)(1), Mumbai vs. Millennium Appliances, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1389/MUM/2023[2016-2017]Status: DisposedITAT Mumbai15 Sept 2023AY 2016-2017

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – 3(2)(1) V. M/S. Millennium Appliances India Ltd., 17Th Floor, C Wing Mittal Court Room No. 608, 6Th Floor Nariman Point, Mumbai - 400021 Aayakar Bhavan, M.K. Road Mumbai - 400020 Pan: Aaccm7838D (Appellant) (Respondent)

Section 14A

disallowance u/s. 14A in book Page No. | 6 M/s. Millennium Appliances India Ltd., profits for section 115JB of the Act and determined the book profits at ₹.5,29,56,330/-. 5. Aggrieved with the above order assessee preferred an appeal before the Ld.CIT(A) and filed the detailed submissions before ... Millennium Appliances India Ltd., 115JB(2) without having resort to section 14A r.w.r. 8D of the Income-tax Rules while computing book profit u/s. 115JB" 4. "The appellant craves leave to amend, alter, delete or add grounds which may be necessary.” 7. Considered the submissions

ACIT(Ltu-1), Mumbai vs. M/S. Tcs Ltd, Mumbai

ITA 5904/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

assessee filed the return of income for assessment year 2014-15 on 28/11/2014 declaring a total income of Rs.13450,10,54,480/- and the book profits under section 115JB of the Income-tax Act, 1961 (in short, „the Act) declared at Rs.12725,88,06,235/- The case was selected

Tata Consultancy Serrvices Limited, Mumbai vs. DCIT-1, Mumbai

ITA 5199/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

assessee filed the return of income for assessment year 2014-15 on 28/11/2014 declaring a total income of Rs.13450,10,54,480/- and the book profits under section 115JB of the Income-tax Act, 1961 (in short, „the Act) declared at Rs.12725,88,06,235/- The case was selected

ACIT, Circle-2, Faridabad vs. Nhpc Ltd., Faridabad

Appeal of the assessee is allowed

ITA 5299/DEL/2019[2016-17]Status: DisposedITAT Delhi14 Sept 2023AY 2016-17

Bench: SHRI SHAMIM YAHYA (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Sanjay Pandey, CIT DR
Section 115JSection 14ASection 80

right in law in deleting addition of Rs.139,00,00,000/- made under normal provision as well as on book profit by the Assessing Officer under section 14A of the Act by applying Rule 8D? 2. "Whether on the facts and in circumstances of the case ... right in law in deleting disallowance of Rs.6,68,59,118/- made by the AO in computing the book profit u/s 115JB on account of provisions made for gratuity, leave encashment, post- retirement medical benefits, LTC, Baggage allowance and Matching Contribution on Leave Encashment even though the assessee has failed

Nhpc Ltd, Faridabad vs. ACIT, Circle-II, Faridabad

Appeal of the assessee is allowed

ITA 4915/DEL/2019[2016-17]Status: DisposedITAT Delhi14 Sept 2023AY 2016-17

Bench: SHRI SHAMIM YAHYA (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Sanjay Pandey, CIT DR
Section 115JSection 14ASection 80

right in law in deleting addition of Rs.139,00,00,000/- made under normal provision as well as on book profit by the Assessing Officer under section 14A of the Act by applying Rule 8D? 2. "Whether on the facts and in circumstances of the case ... right in law in deleting disallowance of Rs.6,68,59,118/- made by the AO in computing the book profit u/s 115JB on account of provisions made for gratuity, leave encashment, post- retirement medical benefits, LTC, Baggage allowance and Matching Contribution on Leave Encashment even though the assessee has failed

Malco Energy Ltd., Mumbai vs. Asst CIT Circle-10(2)(2), Mumbai

ITA 7314/MUM/2019[2015-16]Status: DisposedITAT Mumbai13 Sept 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm Asst. Commissioner Of Income-Tax Malco Energy Limited Circle 10(2)(2), Vedanta House, Room No.209, 75, Nehru Road, Ville- 2Nd Floor, Parle, Vs. Mumbai-400 099 Aaykar Bhavan Maharashtra, India Maharishi Karve Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aahcs6896A Assessee By : Ms. Fereshte Sethna, Shri Mrunal Parekh, Ars Revenue By : Shri Manoj Kumar, Cit Dr

For Appellant: Ms. Fereshte SethnaFor Respondent: Shri Manoj Kumar, CIT DR
Section 115J

Assessment Malco Energy Ltd.; A.Y.2015-16 order total income of the assessee was determined at ₹Nil, as per normal computation of total income and book profit under section 115JB of The Income-Tax Act, 1961 (the Act) was determined at ₹155,43,34,549/– against revised return filed by the assessee ... total income of the Appellant at Rs 145,63,51,016/- under normal provisions of the Act and Rs.155,43,34,549/- as revised book profit u/s 115JB of the Act, against the returned income of Rs. NIL and book-loss of (Rs.44,56,65,452/-), by making the impugned

DCIT Cir 5(3)(2), Mumbai vs. The Great Eastern Shipping Co. Ltd, Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 2077/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5 Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

made under section 14 A of the act and under the normal computation of income is also required to be added back for computing book profits under section 115JB of the act. The appellant submits that section 115JB of the act is a separate code by itself and the provisions ... section 14 A and rule 8D cannot be applied for computing the book profits under section 115JB of the act 05. Briefly stated the fact shows that the assessee company is engaged in the business of shipping, property development and finance operations including dealing in shares, securities, mutual funds

The Great Eastern Shipping Co. Ltd, Mumbai vs. Asst CIT Cir 5(3)(2), Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 1597/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

made under section 14 A of the act and under the normal computation of income is also required to be added back for computing book profits under section 115JB of the act. The appellant submits that section 115JB of the act is a separate code by itself and the provisions ... section 14 A and rule 8D cannot be applied for computing the book profits under section 115JB of the act 05. Briefly stated the fact shows that the assessee company is engaged in the business of shipping, property development and finance operations including dealing in shares, securities, mutual funds

The Great Eastern Shipping Co. Ltd, Mumbai vs. Asst CIT Cir 5(3)(2), Mumbai

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 374/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Sept 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

made under section 14 A of the act and under the normal computation of income is also required to be added back for computing book profits under section 115JB of the act. The appellant submits that section 115JB of the act is a separate code by itself and the provisions ... section 14 A and rule 8D cannot be applied for computing the book profits under section 115JB of the act 05. Briefly stated the fact shows that the assessee company is engaged in the business of shipping, property development and finance operations including dealing in shares, securities, mutual funds