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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

DCIT, Gurgaon vs. Omaxe Limited, New Delhi

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

ITA 2403/DEL/2025[2014]Status: DisposedITAT Delhi24 Oct 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roydcit, Vs. Omaxe Limited, Gurugram. 7, Local Shopping Centre, Kalkaji, New Delhi – 110 016. (Pan : Aaaco0171H) (Appellant) (Respondent) Assessee By : Shri Akshat Jain, Ca Shri Rajat Jain, Ca Revenue By : Ms. Garima Mathur, Sr. Dr Date Of Hearing : 23.09.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Delhi-44 Dated 13.02.2025 For Ay 2014-15 Raising Following Grounds Of Appeal :- “(I) Whether Ld. Cit(A) Has Erred In Allowing Deduction U/S 80Ib (10) Of The Act To The Tune Of Rs.5,22,08,123/- In Respect Of The Profits From Housing Project Which Are Group Housing Scheme Of Multi-Storied Flats In The Projects Namely M/S Royal Residency, Ludhiana? (Ii) Whether Ld. Cit(A) Has Erred In Following The Order Of Ld. Cit(A) - 19 For The Ay 2011-12 Wherein It Was Held That The Aforesaid Group Housing Scheme Is Separately Satisfying The Conditions Laid Down In The Provisions Of 2 Section 80Ib(10) Despite Observing That The Consolidated Approval Of The Local Authority Is For The Entire Project? (Iii) Whether The Decision Of Ld. Cit(A) Does Not Suffer From The Vice Of Perversity? (Iv) Whether Ld. Cit(A) Has Erred In Law & On Facts By Determining The Credit Spread At 500 Basis Points, Relying Upon The Guidelines Issued By Reserve Bank Of India For External Commercial Borrowing? (V) Whether Ld. Cit(A) Has Erred In Law & On Facts By Ignoring The Judgment Of Hon'Ble High Court?”

For Appellant: Shri Akshat Jain, CAFor Respondent: Ms. Garima Mathur, Sr. DR
Section 80I

filed on 13.10.2010 declaring income at income at Rs. 23,01,19,070/- under the normal provisions of the Act. However, book profits at Rs. 79,06,38,634/- were reported u/s 115JB of the Act. Assessment order was passed on 26.05.2014 computing total income