Section 115JA of the Income Tax Act

For calculation of deduction under Section 80HHC, if total interest is netted off after adjusting interest paid and received, the 90% reduction specified in Explanation (baa) is not applicable.

Export incentives, such as DEPB (Duty Entitlement Pass Book) and advance license benefits, constitute income taxable on an accrual basis under Section 28 of the Income-tax Act. Profit arising on the transfer of DEPB is not eligible for deduction under Section 80HHC.

For computing book profits under Section 115JB, an Assessing Officer's power is limited to examining duly certified books and making adjustments only as per the Explanation. A provision for bad and doubtful debts, being a diminution in the value of an asset (receivable), does not constitute a 'provision for liability' under Clause (c) of the Explanation and therefore cannot be added back.

Book profits, as determined from the financial statements prepared under the Companies Act, are generally immune from arbitrary alteration by tax authorities when computing minimum alternate tax (MAT) under Section 115JB, except for specific adjustments mandated by income-tax law.

No addition can be made in a search assessment under Section 153A or 153C for assessments that have become final, unless incriminating material is found during the search or assessment proceedings. The absence of such material also impacts the invocation of revisionary jurisdiction under Section 263.

The classification of a government subsidy as either a revenue or capital receipt depends on its object and purpose. If the subsidy is given to enable the assessee to set up a new unit or expand an existing one, it is a capital receipt; if it is to meet recurring expenses, it is a revenue receipt.

Interest under sections 234B and 234C is leviable for failure to pay advance tax, even when the income tax is ultimately computed under Minimum Alternate Tax (MAT) provisions, specifically sections 115JA or 115JB. This ruling clarified the law, overturning previous interpretations.

A decision's binding effect relies on the points decided, not on whether specific arguments were considered. A precedent remains authoritative even if poorly argued or reasoned, provided the relevant point was addressed.

Exempt capital gains must be considered when computing book profits under Section 115JB. Book profits cannot be arbitrarily adjusted.

Transfer pricing adjustments cannot be added back to book profits under section 115JB of the Income-tax Act, as they are not among the permissible adjustments listed in Explanation I to section 115JB(2). Exempt capital gains must be considered when computing book profits under section 115JB.