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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

Assistant Commissioner of Income Tax, Jaipur vs. Jaipur Telecom Private Limited, Jaipur

In the result, the appeal of the revenue is dismissed

ITA 31/JPR/2024[2014-15]Status: DisposedITAT Jaipur01 Jul 2024AY 2014-15

Bench: Hon’Ble High Court Against The Order Dated 15.03.2023 Of Hon’Ble Itat & The Matter Is Subjudice?”

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 115JSection 143(3)Section 263Section 271(1)(c)

addition was made only due to MAT calculation on sale of fixed assets which was Tax neutral over the succeeding years by MAT credit. The assessee requested to drop the penalty proceedings initiated against the AY 2014-15. The ld. AO noted that the assessee itself included the income arising

Rajasthan Renewable Energy Corporation Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

ITA 387/JPR/2024[2014-15]Status: DisposedITAT Jaipur25 Jun 2024AY 2014-15

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 154Section 250

including interest. 3. From the order u/s 154 of the Act, it transpires that tax of Rs. 6.27crore was charged after allowing MAT credit of Rs. 3.16 crore pertaining to the period i.e. from Assessment Years 2008-09 to Assessment Year 2013-14, but allowable MAT credit ... opportunity of being heard. Another ground raised by the ld. AR for the assessee is that while passing the impugned order, and thereby reducing MAT credit from Rs. 3.16 crore to Rs. 55.46 lacs. 7. Learned DR for the department has contended that despite service of notice, there

DCIT 3(3)(1), Mumbai vs. Sp Port Maintenance Private Limited, Mumbai

ITA 3896/MUM/2023[2018-19]Status: DisposedITAT Mumbai25 Jun 2024AY 2018-19

Bench: Ms. Padmavathy S. & Shri. Raj Kumar Chauhan

Section 115JSection 142(1)Section 143(2)Section 14ASection 250

taxes is allowed, after due verification. Interest u/s. 234A, 234B, 234C and 234C is charged as per law, as applicable in assessee's case. MAT credit available if any, is allowed. Tax Computation Sheet in ITNS-150A is enclosed herewith, which forms part of this order. Demand Notice and Challan

DCIT 3(3)(1), Mumbai vs. Sp Port Maintenance Private Limited, Mumbai

In the result, appeal filed by the revenue are dismissed in the above terms

ITA 3895/MUM/2023[2017-18]Status: DisposedITAT Mumbai25 Jun 2024AY 2017-18

Bench: Ms. Padmavathy S. & Shri. Raj Kumar Chauhan & Dcit 3(3)1 Vs. Sp Port Maintenance Private Room No. 522, Aaykar Bhavan, M. Limited K. Road, Churchgate, Mumbai – 41/44, Shapoorji Pallonji 400 020. Centre Mumbai, Colaba S.O, Pan: Aaxcs6219B Mumbai – 400 005. (Appellant) (Respondent)

Section 115JSection 142(1)Section 143(2)Section 14ASection 250

taxes is allowed, after due verification. Interest u/s. 234A, 234B, 234C and 234C is charged as per law, as applicable in assessee’s case. MAT credit available if any, is allowed. Tax Computation Sheet in ITNS-150A is enclosed herewith, which forms part of this order. Demand Notice and Challan

Sjlt Textiles Private Limited, Chennai vs. ACIT, Corp Cricle 6(2), Nungambakkam Chennai

In the result the appeal is partly allowed for statistical purposes

ITA 671/CHNY/2023[2017-18]Status: DisposedITAT Chennai12 Jun 2024AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.671/Chny/2023 निर्धारण वर्ा /Assessment Years: 2017-18 Sjlt Textiles Private Limited Asst. Commissioner Of Income Tax, 2E Second Floor, Prince Arcade Corp Circle-6(2), Chennai. Cathedral Road, Chennai-86 [Pan: Aaics2028M] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Ms.Sandyaarthi, Ca प्रत्यर्थी की ओर से /Respondent By : Shri Arv Srinivasan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.06.2024 घोषणा की तारीख /Date Of Pronouncement : 12.06.2024

For Appellant: Ms.Sandyaarthi, CAFor Respondent: Shri ARV Srinivasan, Addl.CIT
Section 115BSection 250Section 69A

ground of appeal nos. 2 to 11 raised by the assessee are partly allowed. 11.0 Ground of appeal No.11 regarding non-consideration of eligible MAT credit while computing tax liability is consequential in nature. The AO is directed to, after determination of taxable income, allow eligible MAT credit

Bloom Seal Containers Pvt Ltd, Mumbai vs. The Deputy Commissioner of Income Tax, Centralized Processing Centre It Dept, Bangalore

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

ITA 2591/MUM/2023[2017-18]Status: DisposedITAT Mumbai31 May 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhribloom Seal Containers Vs. Dcit, Cpc, Pvt. Ltd. It Department, 4Th Floor, Ready Money Bengluru Terrace, Dr. Annie Besant Road, Worli Naka, Worli, Mumbai-400018 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Appellant .. Respondent

For Appellant: Shri Kirit KamdarFor Respondent: Shri Himanshu Kumar
Section 115JSection 143(1)Section 234Section 234CSection 250Section 40A(7)Section 43B

allowed. Without prejudice to ground Nos 1 and 2 above, Ground No. 3 : Non allowance of set off of MAT credit: 3.1 On the facts and in the circumstances of the case and in law, the CIT(A) erred in upholding the action of the CPC in not allowing ... available tax credit under section 115Jaa of the Act (MAT Credit) against the tax payable on the income assessed under section 143(1) of the Act. 3.2 .The appellant, therefore, praywes that tax credit under section 115JAA be allowed to be set off against the tax payable on the assessed

Yojaka India Pvt Ltd, Mangaluru vs. Asst Commissioner of Income Tax Circle-1(1) and Tps, Mangaluru

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

ITA 924/BANG/2023[2013-14]Status: DisposedITAT Bangalore29 May 2024AY 2013-14

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Smt. M.R. Vanaja, AdvocateFor Respondent: Smt. Shamala, D.D., Addl.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 154Section 80I

case are that the AO completed assessment u/s. 143(3) of the Act on 08.03.2016. The AO issued rectification order dated 29.03.2021 observing that MAT credit for AY 2012-13 was allowed and later it came to notice that the assessment for AY 2012-13 was completed ... disallowing claim of deduction u/s. 80IA and tax was payable for AY 2012-13 under normal provisions and not under MAT. Hence no MAT credit was available to be set off in AY 2013-14. The AO accordingly issued notice to withdraw the MAT credit of Rs.71,35,925 allowed

Ctr Manufacturing Industries Private Limited, Pune vs. The Deputy Commissioner of Income Tax, Circle 1(1), Pune

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

ITA 347/PUN/2024[2016-17]Status: DisposedITAT Pune21 May 2024AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Ramnath P. Murkunde
Section 10(34)Section 115JSection 143(1)Section 143(2)Section 14ASection 156Section 234BSection 250Section 271(1)(C)Section 271(1)(c)

Appellant in relation to disallowance under section 14A r.w. Rule 80, Denial of claim under section 35(2AB) of the Act, non-grant of MAT credit and thereby the order passed by the Ld. CIT(A) is liable to be set-aside; 2. erred in passing an order under section ... Authority was just to approve the in-house R&D facility and not to approve the actual expenditure eligible for deduction; Non-grant of MAT credit under section 115JAA of the Act to the extent of Rs 1,58,91,322.00 9. erred in not granting MAT credit of Rs.1

Gati Kintetsu Express Pvt. Ltd, Maharashtra and Mumbai vs. Dy. Commissioner of Income Tax, Circle 14(1)(2), Mumbai, Maharashtra and Mumbai

ITA 2829/MUM/2023[ASS YEAR 2013-2014]Status: DisposedITAT Mumbai13 May 2024

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Mr. Madhur Agrawal
Section 143(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP

R A K Ceremics India Private Limited, Hyderabad vs. DCIT, Circle-3(1), Hyderabad

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

ITA 61/HYD/2023[2014-15]Status: DisposedITAT Hyderabad09 May 2024AY 2014-15

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2014-15 R.A.K. Ceramics India Vs. The Deputy Commissioner Of Private Limited, Income Tax, P.O Box No.11, Circle 3(1), Adb Road, Samalkot, Hyderabad. Andhra Pradesh. Pin – 53340, Pan : Aaccr6424N. (Appellant) (Respondent) Assessee By: Shri Aliasagar Rampurwala, C.A. Revenue By: B. Balakrishna – Cit Dr Date Of Hearing: 01.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2014-15 Arises From The Assessment Order Of The Deputy Commissioner Of Income Tax, Circle – 3(1), Hyderabad Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 254 Of The Income Tax Act Dated 28.11.2022. 2. The Grounds Raised By The Assessee Read As Under :

For Appellant: Shri Aliasagar Rampurwala, C.AFor Respondent: B. Balakrishna – CIT DR
Section 143(2)Section 143(3)Section 144C(5)Section 271BSection 92C

facts and in the circumstances of the case and in law, Ld. AO has erred in crystalizing tax demand by ignoring the MAT credit carried forward from previous assessment years.” 3. The brief facts of the case are that assessee is a wholly owned subsidiary of RAK Ceramics ... assessee i.e., ground No.5 is with respect to consideration. With respect to this ground, we direct the Assessing Officer to grant the MAT credit as admissible in law. Accordingly, this ground is allowed. 17. In the result, the appeal of the assessee is partly allowed. Order pronounced in the Open

Srei Infrastructure Finance Limited, Kolkata vs. ACIT, Cir-11(1), Kol, Kolkata

In the result, appeal of the assessee is allowed

ITA 1157/KOL/2023[2017-18]Status: DisposedITAT Kolkata29 Apr 2024AY 2017-18

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No.1157/Kol/2023 Assessment Year: 2017-18 Srei Infrastructure Finance Ltd. ………. Appellant (Pan: Aaacs1425L) Vs. Acit, Circle-11(1), Kolkata ……. Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Sm. Lata Goyal, Aca Appeared For Appellant Shri S. Datta, Cit, Dr Appeared For Respondent . Date Of Hearing : 07.02.2024 Date Of Pronouncing The Order : 29.04.2024 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2017-18 Is Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 05.09.2023 Arising Out Of The Assessment Order U/S. 154 R,W,S, 143(3) Of The Act By Acit, Circle-11(1), Kolkata Dated 12.07.2022. 2. Grounds Of Appeal Raised By The Assessee Are Reproduced As Under: “1. That On The Facts & In The Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeal), [Here- In- After Referred To As Ld. Cit(A)] Was Not Justified & Grossly Erred In Not Granting The Interest U/S. 244A Of The Income Tax Act, 1961 ('The Act').

Section 115JSection 139(1)Section 143(2)Section 154Section 244ASection 244A(2)Section 250

assessment order passed on 29.05.2021. Thereafter, rectification petition was filed on 06.06.2022 for correcting the MAT computation after giving MAT credit available for set off u/s. 115JJAA of the Act. Ld. AO passed rectification order on 12.07.2022 and issued a refund of Rs.25,72,14,141/- which comprised ... furnished on 30.03.2019 the assessee had claimed refund of only Rs.2,89,36,036/- and it was only on account of set off of MAT credit u/s. 115JJAA of the Act that the claim of refund has increased and such claim for set off of MAT credit u/s. 115JJAA Page

Dabur India Ltd, New Delhi vs. DCIT Circle 7(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2593/DEL/2023[2015-16]Status: DisposedITAT Delhi16 Apr 2024AY 2015-16

Bench: Shri Kul Bharat & Shri M. Balaganeshdabur India Ltd, Vs. Dcit, 8/3, Asaf Ali Road, Circle-7(1), New Delhi New Delhi (Appellant) (Respondent) Pan:Aaacd0474C Assessee By : Shri M. P. Rastogi, Adv Shri Shivam Malik, Adv Revenue By: Shri Vivek Kumar Upadhyay, Sr. Dr Date Of Hearing 10/04/2024 Date Of Pronouncement 16/04/2024

For Appellant: Shri M. P. Rastogi, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 115Section 115JSection 143Section 154Section 234BSection 90Section 90ASection 91

raised the following grounds of appeal before us:- “1. That the AO and CIT (Appeals) both ought not to have restricted the claim of MAT credit to the extent of Rs. 12,61,33,173/- against the claim of Rs. 14,29,09,497/- (Rs.12 ... Appeals) have erred on facts and under the law, while interpreting the provision of Section 115-JAA of IT Act meant for allowing MAT credit paid in earlier year, that the tax does not include surcharge and education cess and consequently the disallowance of surcharge and education cess Rs. Dabur

Koomber Properties & Leasing Co. Pvt. Ltd., Kolkata vs. DCIT, Cpa. Bangalore., Bangalore

In the result, the appeal of the assessee is allowed in the above terms

ITA 1250/KOL/2023[2018-19]Status: DisposedITAT Kolkata19 Mar 2024AY 2018-19

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 143Section 143(1)Section 250

Sources: Rs.36,29,000/- (d) Total Income ; Rs.1,08,02,162/- R/Off to : Rs.1,08,02,160/- The tax liability thereon after adjustment of MAT credit available and interest was Rs.25,09,840/- which was fully met. The DCIT, CPC, Bangalore (Assessing Officer) sent a communication dated 17.03.2C19 proposing

Ge Hydro France, New Delhi vs. DCIT, Circle-1(3)(1), International Taxation, New Delhi

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

ITA 2086/DEL/2022[2019-20]Status: DisposedITAT Delhi13 Mar 2024AY 2019-20

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Aditya Vohra, Adv
Section 143(3)Section 144C(13)Section 40Section 44B

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI C. N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH

Ge Hydro France, New Delhi vs. DCIT, Circle-1(3)(1), International Taxation, New Delhi

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

ITA 2085/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Mar 2024AY 2018-19

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Aditya Vohra, Adv
Section 143(3)Section 144C(13)Section 40Section 44B

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI C. N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH

Sarvottam Caps Pvt. Ltd., Kolkata vs. PCIT-2, Kolkata

In the result, ITA No. 202/KOL/2021 is dismissed

ITA 202/KOL/2021[2015-16]Status: DisposedITAT Kolkata11 Mar 2024AY 2015-16

Bench: Sri Rajesh Kumar & Sri Anikesh Banerjee

Section 115JSection 143(3)Section 14ASection 263

book profit u/s 115JB of the Act both the amounts are not added with the book profit. Accordingly, during calculation of the MAT credit u/s 115JA of the Act the ld. AO had allowed more credit to the assessee which was amounted ... computed for Rs. 3,09,74,317/- and in Section 115JB tax on book profit was computed for Rs. 2,25,90,022/- and MAT credit was allowed for Rs. 83,84,295/- (Rs. 3,09,74,317/- - Rs, 2,25,90,022/-). (iv) However, as per explanation below Section

Associated Soapstone Distributing Co Private Limited, Jaipur vs. Principal Commissioner of Income Tax -2, Jaipur

In the result, the appeal filed by the assessee is allowed as indicated

ITA 243/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19
For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 139(1)Section 143(2)Section 143(3)Section 14ASection 263Section 36(1)(ii)Section 37Section 43B

delayed payment of TDS not eligible for deduction under Section 36(1)(ii) or Section 37 [“Issue No. 2”]. e Excess MAT Credit, pertaining to AY 2016-17, Rs. 96,13,814 erroneously allowed. [“Issue No. 3”] 3 ITA243/JP/2023 ASSOCIATED SOAPSTONE DISTRIBUTING CO. PVT LTD. VS Pr.CIT-2, JAIPUR ... liable to disallowance u/s 40(a)(i) of the Act. “°2.5 In the computation sheet enclosed with the assessment order the FAO has allowed MAT credit u/s 115AA of Rs.2,12,99,115/-. In the ITR claimed MAT credit of Rs.96,13,814/- relating to A.Y. 2016-17 and that

ACIT Circle-7(2), New Delhi vs. Dhruv Milkose Pvt Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 8431/DEL/2019[2015-16]Status: DisposedITAT Delhi08 Feb 2024AY 2015-16

Bench: Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Pawan Chakrapani, FCAFor Respondent: Shri Vivek Kumar Upadhyay, Sr.DR
Section 143(3)Section 56(2)(viib)

taken at 20.0075% after considering the fact that the appellant is eligible for deduction u/s. 80IA of the Act and is also eligible for MAT Credit; v. Since the shares have been issued to the holding company, there was no rationale to charge excess premium as the appellant could have ... pertaining to earlier years to be set off against the assessed income. Ground no. 6 of the appeal is related to the claim of MAT credit pertaining to AY 2013-14 to be adjusted against the tax liability. In this regard, the AR has also submitted that the appellant

Infrastructure Leasing and Financial Services Ltd, Mumbai vs. Addl /Jt/ACIT/NFAC Delhi, Delhi

In the result, appeal of the assessee is partly allowed

ITA 1554/MUM/2021[2016-17]Status: DisposedITAT Mumbai31 Jan 2024AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

Section 115JSection 143(3)Section 14ASection 92B

software amounting to Rs.59,32,663 8 Disallowance of brought forward losses and 20 unabsorbed depreciation of Rs.27,77,31,728 9 Disallowance of MAT credit u/s 115JAA 21 10 Disallowance of deduction of education cess and 22 secondary and higher education cess amounting to Rs.6 ... been stated that this issue is purely academic and consequential and therefore, same does not require any adjudication and as far as disallowance of MAT credit u/s.115JAA, the ld. AO to examine the claim of MAT credit and allow in accordance with law. 18. Lastly, with regard to disallowance

United Spirits Limited, Bangalore (Successor to Sw Finance Co Limited- Formerly Known As Shaw Wallace Breweries Limited), Bangalore vs. The JCIT Special Range 7, Bangalore

The appeal of the assessee is partly allowed

ITA 3201/MUM/2014[2007-08]Status: DisposedITAT Mumbai02 Jan 2024AY 2007-08

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

Section 115JSection 14ASection 234BSection 250Section 35D

authorities below erred in disallowing merger expenses to the extent of Rs.31,25,792/-. 4. That the authorities below erred in not allowing MAT credit as per section 115JAA of the Act. 5. The appellant denies the liability for interest u/s.234B. Further interest u/s 234B if any can be levied ... Accordingly the additional ground is allowed in favour of the assessee. 14. Ground no.4 pertains to lower authorities not allowing the MAT credit as per section 115JAA. For AY 2006-07 the assessee has paid tax under section 115JB of the Act and accordingly claimed the credit for MAT during