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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

Fivd India Consulting Pvt Ltd, Gurgaon vs. DCIT, Central Circle-1(1), Gurgaon

In the result, appeal of the assessee is allowed for statistical purpose in the terms aforesaid

ITA 3877/DEL/2025[2023-24]Status: DisposedITAT Delhi28 Nov 2025AY 2023-24

Bench: Shri Vikas Awasthy& Shri S Rifaur Rahmanआअसं.3877/िद"ी/2025 (िन.व. 2023-24) Fivd India Consulting P.Ltd., 1022-1027, 10Th Floor, Emaar Digital Green, Sector-21, Golf Course Ext Road, Near Golf Ext., Gurgaon, Haryana 122002 ...... अपीलाथ"/Appellant Pan: Aaecf-3663-P बनाम Vs. Deputy Commissioner Of Income Tax, ....."ितवादी/Respondent Circle 1(1), Gurgaon, Haryana 122002 Assessee By : Shri Y K Sud, Chartered Accountant Department By: Ms. Monika Singh, Cit(Dr) सुनवाई क" ितिथ/ Date Of Hearing : 18/11/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 28/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)/Additional/Joint Commissioner Of Income Tax(Appeals), Bhubaneswar (Hereinafter Referred To As 'The Cit(A)') Dated 04.04.2025, For Assessment Year 2023-24. 2. Shri Y K Sud, Appearing On Behalf Of The Assessee Submits That The Short Issue In Present Appeal Is Disallowance Of Assessee’S Claim Of Deduction U/S.80Iac Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). He Submitted That The Assessee Is Engaged In The Business Of Interior Design, Architectural Advisory Services

For Appellant: Shri Y K Sud, Chartered AccountantFor Respondent: Ms. Monika Singh, CIT(DR)
Section 115JSection 139Section 143(1)Section 44ASection 80I

assessee filed its return of income on 30.11.2023 claiming deduction u/s.80IAC amounting to Rs.18,57,30,737/-. The assessee calculated its book profits u/s. 115JB and offered Rs.18,43,88,071/- to tax. The return of the assessee was processed u/s.143(1) of the Act. While processing return of income

DCIT Circle 1(1), New Delhi vs. Acme Tele Power Ltd. (Now Known As Acme Cleantech Solution Ltd.), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

such warranty is extended to the customer alongwith the sales of the goods is an ascertained liability and should not be added to the book profit u/s 115JB of the Act. 27. From the perusal of the Financial statements of the assessee for the year under appeal as available ... claimed, no disallowance is required to be made. Further since it is ascertained liability, no addition is required to be made in the book profits u/s 115JB of the Act. With these directions, Ground of appeal Nos.8 & 9 raised by the assessee are partly allowed for statistical purposes

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

such warranty is extended to the customer alongwith the sales of the goods is an ascertained liability and should not be added to the book profit u/s 115JB of the Act. 27. From the perusal of the Financial statements of the assessee for the year under appeal as available ... claimed, no disallowance is required to be made. Further since it is ascertained liability, no addition is required to be made in the book profits u/s 115JB of the Act. With these directions, Ground of appeal Nos.8 & 9 raised by the assessee are partly allowed for statistical purposes

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

such warranty is extended to the customer alongwith the sales of the goods is an ascertained liability and should not be added to the book profit u/s 115JB of the Act. 27. From the perusal of the Financial statements of the assessee for the year under appeal as available ... claimed, no disallowance is required to be made. Further since it is ascertained liability, no addition is required to be made in the book profits u/s 115JB of the Act. With these directions, Ground of appeal Nos.8 & 9 raised by the assessee are partly allowed for statistical purposes