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“MAT credit”

Special Rate ProvisionsSection 115JAASection 115JAA334 judgments

The decision most relied on for MAT credit is CIT v. K. Srinivasan (83 ITR 346), cited in 129 judgments on BharatTax.

Leading authorities on MAT credit

CIT v. K. Srinivasan
83 ITR 346 · 1972 · Supreme Court
129
citing judgments

The term 'tax' includes surcharge and cess. Surcharge and additional surcharge are considered components of income tax, which can be levied as a basic charge, surcharge, special surcharge, and additional surcharge.

Rain Commodities Ltd. v. DCIT
41 DTR 449 · 2010 · ITAT
71
citing judgments

The ITAT Special Bench in Rain Commodities Ltd. held that certain capital receipts, such as forfeited share warrants, if credited to the profit and loss account, are liable for book profits tax under Section 115JB (Minimum Alternate Tax).

Allied Motors v. CIT
297 ITR 322 · 2008 · Supreme Court
59
citing judgments

An amendment to a section is declaratory and clarifies the existing legal position, rather than introducing a new rule.

CIT v. Tulsyan NEC Ltd.
330 ITR 226 · 2011 · Supreme Court
39
citing judgments

A form prescribed under the Income-tax Rules cannot override the parent statute; the set-off of MAT credit balance against tax is not dependent on the computation of interest under section 234B.

Allied Motors (supra); CIT v. Raman Lal Hathi
217 CTR 105 · Reported
28
citing judgments

Amendments to Sections 234A, 234B, and 234C of the Income-tax Act, 1961, are curative and have retrospective effect, intended to clarify and remove anomalies. Minimum Alternate Tax (MAT) credit must be set off against tax payable before computing advance tax liability to avoid absurd results.

Finance Ltd. v. DCIT
395 ITR 291 · 2017 · High Court
26
citing judgments

MAT credit granted under section 115JAA should be inclusive of surcharge and cess.

CIT v. Vacment India
369 ITR 304 · 2014 · High Court
23
citing judgments

The High Court holds that tax credit cannot be claimed on surcharge and education cess. The calculation of MAT credit should be done after applying surcharge and education cess.

SREI Infrastructure Finance Ltd. v. DCIT
72 Taxmann.com 239 · 2016 · High Court
15
citing judgments

MAT credit under Section 115JAA must be set off against the total tax liability, including surcharge and cess. This implies that cess forms part of the tax for the purpose of MAT credit adjustment.

Judgments citing MAT credit

Jubilant Ingrevia Limited, Bhartiagram vs. Assistant Commissioner of Income Tax, Moradabad

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

ITA 5851/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanjubilant Ingrevia Ltd, Vs. Acit-1, Bhartiagram Bhartia Gram, So Moradabad, Up Dhanaura, Jyotiba Phule Nagar, Uttar Pradesh (Appellant) (Respondent) Pan: Aaecj6722D

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Jitendra Singh, CIT DR
Section 115Section 143(1)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 154Section 234ASection 234CSection 270A

That on the facts and circumstances of the case and in law, the Ld. ACIT erred in not allowing the set-off of available MAT credit under section 1151AA of the Act against the erroneous tax liability determined in the impugned assessment order passed under section 143(3) r.w.s 144C

Repro India Limited, Lower Parel, Mumbai vs. Commissioner of Income Tax (Appeals), Mumbai

The appeal of the assessee is partly allowed

ITA 6698/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 143(3)Section 144BSection 250

making addition of Rs. 35,79,78,081/-. 3. Before the CIT(A), the assessee challenged the additions and also raised issues relating to MAT credit and set-off of brought forward unabsorbed depreciation. The CIT(A) partly allowed the appeal by directing re-computation of income on certain computational ... erred in not adjudicating the additional grounds of appeal raised by the assessee vide its letter dated 23.05.2024 in respect of non-grant of MAT credit of Rs. 16,57,03,298/- to be set off against Income tax liability determined by Assessing Officer. 5. Since the learned Authorised Representative

Savita Sanjay Marghade, Durg, Chhattisgarh vs. Income Tax Officer, Bhilai

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

ITA 849/RPR/2025[2013-14]Status: DisposedITAT Raipur17 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 849/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14) Savita Sanjay Marghade, Mig-658, Vs Income Tax Officer, Aaykar Bhavan, Padmanabhpur, Durg, Chhattisgarh. Opposite Geet Talkies, 491001 New Civic Centre, Sector 6 Bhilai Nagar, Chhattisgarh. 490006 Pan: Aktpm6715H (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2013-14 Filed By The Assessee Is Directed Against The Order Dated 17.10.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148Section 249(3)Section 250

आयकर अपीलीय अिधकरण, रायपुर "ायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR "ी पाथ" सारथी चौधरी, "ाियक सद

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

In the result, the appeals filed by the assessee are allowed in the above terms

ITA 712/MUM/2025[2021-22]Status: DisposedITAT Mumbai10 Feb 2026AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 3(12)Section 80

Appeal Centre, Delhi, assessee under section 80-IAB of the Income-tax Act, 1961, along with consequential issues relating to TDS credit, MAT computation, MAT credit, levy of interest and initiation of penalty proceedings. Since the factual matrix, statutory interpretation, and the core controversy are common across all years ... under section 115JB without any adjustment and there was also a clear totalling error in the computation sheet, and that in A.Y. 2021-22 MAT credit under section 115JAA amounting to Rs. 4,58,998 was not granted. It was submitted that these were purely verifiable issues requiring correction

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

ITA 711/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21
Section 3(12)Section 80

claimed by the assessee under section 80-IAB of the Income-tax Act, 1961, along with consequential issues relating to TDS credit, MAT computation, MAT credit, levy of interest and initiation of penalty proceedings. Since the factual matrix, statutory interpretation, and the core controversy are common across all years ... under section 115JB without any adjustment and there was also a clear totalling error in the computation sheet, and that in A.Y. 2021-22 MAT credit under section 115JAA amounting to Rs. 4,58,998 was not granted. It was submitted that these were purely verifiable issues requiring correction

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

ITA 701/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Feb 2026AY 2018-19
Section 3(12)Section 80

claimed by the assessee under section 80-IAB of the Income-tax Act, 1961, along with consequential issues relating to TDS credit, MAT computation, MAT credit, levy of interest and initiation of penalty proceedings. Since the factual matrix, statutory interpretation, and the core controversy are common across all years ... under section 115JB without any adjustment and there was also a clear totalling error in the computation sheet, and that in A.Y. 2021-22 MAT credit under section 115JAA amounting to Rs. 4,58,998 was not granted. It was submitted that these were purely verifiable issues requiring correction

Repro India Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

The appeal is allowed for statistical purposes

ITA 7605/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarrepro India Limited Acit Circle 11Th Floor, B Wing, Sun 8(1)(1), Paradise Business Plaza, Vs. Aayakar Bhavan, Senapati Bapat Marg, Mumbai-400 020 Lower Parel, Mumbai – 400 013 Pan/Gir No. Aaacr0379J (Applicant) (Respondent) Assessee By Shri Vijay Mehta, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 04.02.2026 Date Of Pronouncement 09.02.2026

Section 143(3)Section 144BSection 250

determined by the Assessing Officer himself in the Assessment Order. 6. The Assessing officer has erred in respect of non-grant of MAT credit of Rs. 17,55,03,866/- to be set off against Income tax liability determined by Assessing Officer. 7. The CIT(A) has erred in upholding

Aromatrix Flora (P) Ltd., New Delhi vs. ACIT Circle 1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2100/DEL/2024[2011-12]Status: DisposedITAT Delhi04 Feb 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 80I

fide intent or mens-rea to conceal any income as no additional tax would have been payable as the appellant had sufficient availability of MAT credit and thus a genuine, unintentional mistake of understanding of the statute could not be a basis to levy penalty

Ge India Exports Private Limited, Bangalore vs. DCIT, Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 293/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

raised by the assessee through Ground Nos. 11, 12 and 13 pertain the grant of credit for prepaid taxes, tax deducted at source and MAT credit. 32. We have considered the rival submissions and perused the materials available on record. The grievance of the assessee is that ... correctly allowed credit for advance tax/self-assessment tax paid, TDS appearing in the relevant certificates/Form 26AS, and MAT credit available to the assessee, while computing the tax liability. 32.1 At the outset, we observe that grant of credit for prepaid taxes and TDS is a statutory right of the assessee, subject

DCIT, Bangalore vs. M/S Ge India Export Pvt. Ltd., Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 253/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

raised by the assessee through Ground Nos. 11, 12 and 13 pertain the grant of credit for prepaid taxes, tax deducted at source and MAT credit. 32. We have considered the rival submissions and perused the materials available on record. The grievance of the assessee is that ... correctly allowed credit for advance tax/self-assessment tax paid, TDS appearing in the relevant certificates/Form 26AS, and MAT credit available to the assessee, while computing the tax liability. 32.1 At the outset, we observe that grant of credit for prepaid taxes and TDS is a statutory right of the assessee, subject

Capgemini Technology Services India Limited (Successor to Liquidhub India Private Limited), Pune vs. Assistant Commissioner of Income Tax, Circle 1(1), Pune

In the result, the Appeal filed by the Assessee is allowed

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

additions made in the assessment order under section 143(3) of the Act would simply result in reduction of the available MAT credit to the Appellant, and the Appellant has already given effect to such reduction in the available MAT credit in the subsequent assessment years. 9. The Learned ... before the AO" 7 In this context, the Company submits that payment of the said disallowance has already been made via adjustment in MAT credit as follows: 7.1 The Company had an outstanding MAT credit of INR 5,99,62,79,248 as of April 01, 2022. 7.2. Considering

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Kalpataru Projects International Limited, Gujarat

In the result, the appeal of the assessee bearing ITA No

ITA 6159/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Jan 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Kalpataru Projects Inernational Limited, Gujarat

In the result, the appeal of the assessee bearing ITA No

ITA 6114/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Kalpataru Projects International Limited, Gujarat

In the result, the appeal of the assessee bearing ITA No

ITA 6113/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Kalpataru Projects International Ltd, Gujarat vs. DCIT, CC-3(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5961/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Kalpataru Projects International Ltd, Mumbai vs. DCIT, CC-3(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5960/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Kalpataru Projects International Ltd, Gujarat vs. DCIT, CC-3(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5959/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Jan 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Vijay MehtaFor Respondent: Shri Ritesh Misra, CIT DR
Section 115JSection 139(1)Section 147Section 250Section 90

succession. vi. The applicability of MAT/AMT provisions could be different with different MAT/AMT credit. In the present case, JMC Projects has brought forward MAT credit which has been ignored by the Assessing Officer as he was assessing the assessee who is successor. vii. The time limit for reassessment, revision, rectification

Red Hat India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle 15(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3853/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Jan 2026AY 2016-17
Section 143(3)Section 154Section 254Section 92C

additional ground, are rendered academic and are therefore left open. 19. As regards Grounds No. 4 to 8 relating to grant of TDS credit, MAT credit, foreign tax credit, self-assessment tax, and interest under section 244A of the Act, we direct the Assessing Officer to verify the claims

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

In the result, appeal of the revenue is dismissed

ITA 1549/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-2014

Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri P. J. Pardiwala, Sr. Advocate and Shri C. Naresh, CAFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 10Section 115JSection 143(3)Section 14ASection 90

section 91(1) of the Act. 11.6. Based on the above jurisprudence, parallel interpretation was drawn for giving judicial treatment to Minimum Alternate Tax (MAT) credit in amalgamation cases by the Coordinate Benches of ITAT of Ahmedabad and Mumbai in Adani Gas Ltd v. ACIT in ITA No. 2241/ Ahd/2011 ... Ambuja Cements Ltd. v. DCIT [2019] 179 ITD 436 (Mum), respectively. In these decisions, successor entity was allowed to claim MAT credit despite absence of enabling language in section 115JAA. Thus, in absence of a statutory bar, relief mechanism was judicially recognised to uphold the constitutional governance and object

Bank of India, Mumbai vs. The ACIT-2(1)(1), Mumbai

ITA 1397/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawal

Section 10Section 115JSection 143(3)Section 14ASection 90

section 91(1) of the Act. 11.6. Based on the above jurisprudence, parallel interpretation was drawn for giving judicial treatment to Minimum Alternate Tax (MAT) credit in amalgamation cases by the Coordinate Benches of ITAT of Ahmedabad and Mumbai in Adani Gas Ltd v. ACIT in ITA No. 2241/ Ahd/2011 ... Ambuja Cements Ltd. v. DCIT [2019] 179 ITD 436 (Mum), respectively. In these decisions, successor entity was allowed to claim MAT credit despite absence of enabling language in section 115JAA. Thus, in absence of a statutory bar, relief mechanism was judicially recognised to uphold the constitutional governance and object