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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

JCIT (OSD) I/C. to DCIT Circle-1(3)(1), Mumbai vs. Garware Hi-Tech Films Limited, Mumbai

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

ITA 1133/MUM/2025[2021-22]Status: DisposedITAT Mumbai21 Jul 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeejcit(Osd) I/C. To Dcit Circle- Vs Garware Hi-Tech Films Limited 1(3)(1), Mumbai 50A, Garware House, Swami Room No.540, 5Th Floor, Nityanand Marg, Vile Parle (East) Aayakar Bhavan, M.K. Road, S.O. Mumbai-400 057 Mumbai-400 020 Appellant Respondent

For Appellant: Shri Dalpat ShahFor Respondent: Shri Arun Kanti Datta - CIT DR
Section 115JSection 139(1)Section 143(1)Section 250Section 35(1)(i)Section 41

/2025 Garware Hi-Tech Films Ltd. "On the facts and circumstances of the case and in law the Ld.CIT(A) erred in allow the Mat Credit of Rs. 29,94,40,364/- however the assessee has claimed MAT Credit of Rs. 29,17,19,510/- in ITR, the appellant ... time to file revised return, condonation of delay to revised Mat Credit claim of Rs. 29,94,40,364/-." 3. The brief facts of the case are that the assesse filed the return of income under section 139(1) of the Act and the return was processed under section

Ny Green Energy Private Limited Formely Know As Sunkon Energy Pvt Ltd, Surat vs. DCIT Circle 2(1)(1), Surat

In the result, appeal of the assessee is allowed

ITA 205/SRT/2025[2021-22]Status: HeardITAT Surat18 Jul 2025AY 2021-22

Bench: MS SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)

Section 115JSection 139(1)Section 143Section 143(1)Section 250Section 44ASection 80Section 80I

which mandates 100% of profit to be allowed as exemption 2 115JAA Erroneously disallowed On the facts and circumstances of the eligible MAT credit case as well as law on the mater, the bought forward CIT(A) has erred in disallowing MAT credit bought forward as per section 115JAA ... which explicitly states that MAT credit is respect of brought forward tax credit shall be allowable. 3 253 Prayer The appellant craves leave to add, alter, modify or delete any or all the grounds of appeal during the appeal proceedings. 3. Facts of the case in brief are that assessee

Bharat Bijlee Limited, Mumbai vs. Deputy Commissioner of Income Tax - 6(1)(2), Mumbai

Appeal of the assessee is partly allowed

ITA 1531/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Jul 2025AY 2020-21

Bench: Ms Padmavathy S, Am & Shri Raj Kuamr Chauhan, Jm

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 10(34)Section 143(3)Section 14ASection 263

Further, with reference to Revenue Audit observation reference No. 1011997. it has also been observed from the records that the assessee has claimed MAT credit of Rs. 10,50,90,516/- which has been allowed in the order passed u/s.143(3) rws 1448 dated 06.09.2022, although the assessee company ... eligible was set-off of MAT credit only to the extent of Rs. 10,45,21,020/- as determined in the assessment order for A.Y. 2018-19. Thus, the assessee has been allowed excess credit to the extent of Rs. 5,69,496/-. 3. On examination of the assessment order

Mobite Technologies Pvt. Ltd., Pune vs. ITO, Ward, 7(1), Pune

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

ITA 1258/PUN/2025[2021-22]Status: DisposedITAT Pune10 Jul 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1258/Pun/2025 िनधा"रण वष" / Assessment Year: 2021-22 Mobite Technologies Private V The Income Tax Officer, Limited, S. Ward-7(1), Pune. A-701, Victoria Garden, Nagar Road, Kalyani Nagar, Pune – 411006. Maharashtra. Pan: Aafcm7197J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Smt. Shilpa Nc – Addl.Cit(Dr) Date Of Hearing 03/07/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-10, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 12.02.2025 For A.Y.2021-22, Emanating From The Order U/S.143(1) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Ao Cpc Has Erred In Rejecting Concessional Rate Of Income Tax Of 22% Adopted By Assessee For Calculation Of Tax Liability As Per Itr U/S 115Baa & The Ld. Cit A Erred In Confirming The Same

Section 115Section 115BSection 115JSection 143Section 143(1)Section 234BSection 250

year 6. Alternatively, if the Minimum Alternate Tax (MAT) provisions under Section 115.JB are held applicable, the Assessee prays for allowance of MAT credit in accordance with the provisions of the Act. 7. The CPC has erred in levying additional interest under sections 2348 and 234C, which is not justified ... current financial year is less than 400 Crores. Alternatively, if at all MAT provisions become applicable, it is prayed to your honour to allow MAT credit as per relevant provisions of the Act The CPC has erred in applying provisions of section 115JB and computing the MAT for the year

N.C.John & Sons Private Ltd, Alleppey vs. ITO, Ward 1 & Tps, Alleppey

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

ITA 369/COCH/2025[2011-12]Status: DisposedITAT Cochin30 Jun 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2011-12 N.C. John & Sons Private Ltd. .......... Appellant 16/329, N.C. John Bldgs., Vcnb Raod Vazhicherry, Aleppey 688001 [Pan: Aabcn0264H] Vs. Dcit, Circle-1, Alappuzha .......... Respondent Appellant By: Shri Kirshnakumar A, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.06.2025 Date Of Pronouncement: 30.06.2025

For Appellant: Shri Kirshnakumar A, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 154

proposing to amend the consequential order passed to give effect to the CIT(A)’s order passed on 06.04.2016 on the ground that MAT credit available for set off was Rs. 3.5 lakhs only as against Rs. 17.38 lakhs allowed as per assessment record for AY 2010-11. In response ... notice u/s. 154 of the Act the appellant had pleaded ignorance of any mistake in the set off of MAT credit. In the circumstance, the AO, vide order dated 12.02.2019 passed u/s. 154 of the Act disallowed MAT credit of Rs. 13.81 lakhs. 4. Being aggrieved, an appeal was filed

Asandas & Sons Private Limited, Mehsana vs. The Dy.CIT, Circle- Gandhinagar, Gandhinagar

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

ITA 1854/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 144C(5)Section 920

Return of Income. 2.2. On the facts and circumstances of the case, the learned AO has erred in not granting eligible MAT credit to the Appellant (out of MAT credit brought forward from previous years). 3. Ground No. 3 - Initiation of penalty proceedings under section 271AA ... warranted. 10. Ground No.2 - Computation of Book Profits u/s 115JB. The assessee claims that the AO wrongly computed book profits and failed to grant MAT credit is a verifiable factual matter. Therefore we direct the JAO to examine the revised working and allow appropriate relief after due verification. 11. Ground

Shree Cement Limited, Bangur Nagar vs. ACIT, Central Circle, Ajmer

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

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

said book profit tax liability was computed at Rs. 2,15,71,39,155/- thereby generating MAT credit of Rs. 2,15,71,39,155. After taking credit of total taxes paid for an amount of Rs. 2,32,70,65,210 the appellant has claimed a refund

Pramod Lakra, Deputy Commissioner of Income Tax, Circle -11(1), Kolkata vs. Philips Carbon Black Ltd, Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2459/KOL/2024[2021-22]Status: DisposedITAT Kolkata10 Jun 2025AY 2021-22

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

exclusion of provision for deferred taxes in computation of book profit u/s 115JB of the Act and according to the short granting of MAT credit. Being aggrieved and dissatisfied the revenue preferred an appeal before us. 5. The Ld. D.R challenges the very impugned order thereby submitting that

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Phillips Carbon Black Ltd, Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2458/KOL/2024[2020-21]Status: DisposedITAT Kolkata10 Jun 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

exclusion of provision for deferred taxes in computation of book profit u/s 115JB of the Act and according to the short granting of MAT credit. Being aggrieved and dissatisfied the revenue preferred an appeal before us. 5. The Ld. D.R challenges the very impugned order thereby submitting that

Pramod Lakra, Deputy Commissioner of Income Tax, Circle 11(1), Kolkata vs. Phillips Carbon Black Ltd., Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2457/KOL/2024[2018-19]Status: DisposedITAT Kolkata10 Jun 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

exclusion of provision for deferred taxes in computation of book profit u/s 115JB of the Act and according to the short granting of MAT credit. Being aggrieved and dissatisfied the revenue preferred an appeal before us. 5. The Ld. D.R challenges the very impugned order thereby submitting that

Pramod Lakra, Deputy Commissioner of Income Tax, Circle 11(1), Kolkata vs. Phillips Carbon Black Ltd, Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2456/KOL/2024[2017-18]Status: DisposedITAT Kolkata10 Jun 2025AY 2017-18

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

exclusion of provision for deferred taxes in computation of book profit u/s 115JB of the Act and according to the short granting of MAT credit. Being aggrieved and dissatisfied the revenue preferred an appeal before us. 5. The Ld. D.R challenges the very impugned order thereby submitting that

Pcbl Limited, Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2034/KOL/2024[2020-2021]Status: DisposedITAT Kolkata10 Jun 2025AY 2020-2021

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

exclusion of provision for deferred taxes in computation of book profit u/s 115JB of the Act and according to the short granting of MAT credit. Being aggrieved and dissatisfied the revenue preferred an appeal before us. 5. The Ld. D.R challenges the very impugned order thereby submitting that

Schindler India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax-Range 15(3)(2), Mumbai

ITA 7311/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Jun 2025AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

Section 115Section 115JSection 143(3)Section 36(1)(va)

Ground No. 6: On the facts and circumstances of the case and in law, the Ld. AO has erred in not granting MAT credit of Rs.1,87,30,304 under section 115 JAA of the Act. The Appellant prays that the Ld. AO be directed to allow the MAT credit

Schindler India Pvt. Ltd., Mumbai vs. DCIT-Cir-15(3)(2), Mumbai

ITA 7326/MUM/2017[2013-14]Status: DisposedITAT Mumbai06 Jun 2025AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Ms. Chandani ShahFor Respondent: Shri Ajay Chandra, CIT-DR
Section 115Section 115JSection 143(3)Section 36(1)(va)

Nos.7326/Mum/2017 &7311/Mum/2018 Ground No. 6: On the facts and circumstances of the case and in law, the Ld. AO has erred in not granting MAT credit of Rs.1,87,30,304 under section 115 JAA of the Act. The Appellant prays that the Ld. AO be directed to allow ... MAT credit of Rs.1,87,30,304 as per section 115JAA of the Act. Ground No. 7: On the facts and circumstances of the case and in law, the Ld. AO has computed interest (consequential) of Rs.5,69,46,890 under section 234B of the Act. The Appellant prays that

The South Indian Bank, Thrissur vs. DCIT, Circle 1(1) & Tps, Thrissur

In the result, the appeal by the assessee is dismissed

ITA 284/COCH/2024[2008-2009]Status: DisposedITAT Cochin27 May 2025AY 2008-2009

Bench: Shri Inturi Rama Raoshri Sandeep Singh Karhailthe South Indian Bank Limited, Head Office, Mission Quarters, Tb Road, Thrissur Kerala - 680001 ............... Appellant Pan : Aabct0022F V/S Dcit, Circle – 1(1) & Tps ……………… Respondent Thrissur, Kerala

For Appellant: Shri Naresh C, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115Section 142(1)Section 143(2)Section 143(3)Section 154Section 234BSection 234DSection 250

assessee was assessed at ₹ 256,58,53,626. The Assessing Officer (“AO”), while computing the tax liability for the year under consideration, also granted MAT credit to the assessee amounting to ₹ 22,59,55,822 relating to the assessment years 2006-07 (₹ 649.57 lakh) and 2007-08 (₹ 1609.9 lakh) under ... instead of 30%. b) The rate of education cess has been wrongly mentioned as 2% instead of 3%. c) The section under which MAT credit has been allowed has been wrongly mentioned as 115AA instead of 115JAA. d) After 'balance payable', the section under which interest has been levied

Iljin Automotive Private Limited, Kanchipuram vs. Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1496/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 May 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 143(3)Section 154Section 154(3)

Rs.41,51,390/- on account of disallowance of depreciation. Further, the AO has passed rectification order u/s 154 of the Act and denying MAT credit of Rs.6,64,38,277/- and stated record. For AY 2018-19: 2. Brief facts of the case is that the appellant is a Private ... order u/s 154 of the ITA Nos.1494 to 1496/Chny/2024 (AYs 2016-17 to 2018-19) M/s. ILJIN Automotive Pvt. Ltd. :: 4 :: Act and denying MAT credit of Rs.2,73,59,655/- and stated the mistake is apparent from record. 5. Aggrieved by the aforesaid action

Iljin Automotive Private Limited, Irungattukottai vs. Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1495/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 May 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 143(3)Section 154Section 154(3)

Rs.41,51,390/- on account of disallowance of depreciation. Further, the AO has passed rectification order u/s 154 of the Act and denying MAT credit of Rs.6,64,38,277/- and stated record. For AY 2018-19: 2. Brief facts of the case is that the appellant is a Private ... order u/s 154 of the ITA Nos.1494 to 1496/Chny/2024 (AYs 2016-17 to 2018-19) M/s. ILJIN Automotive Pvt. Ltd. :: 4 :: Act and denying MAT credit of Rs.2,73,59,655/- and stated the mistake is apparent from record. 5. Aggrieved by the aforesaid action

Iljin Automotive Private Limited, Kanchipuram vs. Assistant Commissioner of Income-Tax, Corporate Circle 2(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1494/CHNY/2024[2016-17]Status: DisposedITAT Chennai26 May 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 143(3)Section 154Section 154(3)

Rs.41,51,390/- on account of disallowance of depreciation. Further, the AO has passed rectification order u/s 154 of the Act and denying MAT credit of Rs.6,64,38,277/- and stated record. For AY 2018-19: 2. Brief facts of the case is that the appellant is a Private ... order u/s 154 of the ITA Nos.1494 to 1496/Chny/2024 (AYs 2016-17 to 2018-19) M/s. ILJIN Automotive Pvt. Ltd. :: 4 :: Act and denying MAT credit of Rs.2,73,59,655/- and stated the mistake is apparent from record. 5. Aggrieved by the aforesaid action

Olympus Global Stocks Private Ltd., Delhi vs. PCIT Delhi-7, Delhi

In the result, the appeal of the assessee is allowed

ITA 662/DEL/2022[2015-16]Status: DisposedITAT Delhi21 May 2025AY 2015-16

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2015-16 Olympus Global Stocks Vs. Pcit-7, New Delhi Private Ltd., D-248, Office 103, First Floor, Abhishek Business, Central Gali No. 10, Laxmi Nagar, Delhi – 92 (Pan: Aabco0085F) (Appellant) (Respondent)

For Appellant: Shri Salil Kapoor, Adv., Shri AnilFor Respondent: Ms. Amisha S. Gupta, CIT(DR)
Section 143Section 143(3)Section 14ASection 263Section 3Section 56(2)(viia)

reduced from the book value of the assets while computing the fair market value of the unquoted equity shares. 9. That the amount of MAT credit has to be presented on the asset side as per the proforma of balance sheet in Schedule III of the Companies ... such amount of MAT credit shown as asset actually does not represent the value of any asset. 10. That the order passed by the PCIT under section 263 of the Act is clearly without application of mind. Hence, the notice and order passed under section

Hcl Comnet Systems and Services Limited, Delhi vs. Deputy Commissioner of Income Tax, /Assessment Unit, Income Tax Department

In the result this ground of appeal is allowed

ITA 4867/DEL/2024[2022-23]Status: DisposedITAT Delhi19 May 2025AY 2022-23

Bench: Ms. Madhumita Roy

Section 143(2)Section 143(3)Section 144BSection 35ASection 37(1)Section 4

with direction to allow brought forward business losses or unabsorbed depreciation (if any), compute the income under MAT provisions and allowed set off of MAT credit (if any) in accordance with provisions of Income Tax Act. As far as levy of interest u/s 234B in respect of disallowance of transponder