Section 115JB of the Income Tax Act

Income-tax Act, 2025: s.206

Section 115JB of the Income-tax Act, 1961 corresponds to section 206 (Special provision for minimum alternate tax and alternate minimum tax) of the Income-tax Act, 2025.

Read section 206 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 115JB is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 of the 5,494 judgments on BharatTax that turn on this section.

Leading authorities on Section 115JB

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

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.

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

Bharat Earth Movers v. CIT
245 ITR 428 · 2000 · Supreme Court
901
citing judgments

A business liability that has definitely arisen in an accounting year is deductible even if it needs to be quantified and discharged later, as long as its incurring is certain and can be reasonably estimated.

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).

Judgments on Section 115JB

Amey Madhav Baitule, India vs. ITO Ward 3(1), Kalyan

ITA 8671/MUM/2025[2020-2021]Status: DisposedITAT Mumbai17 Aug 2026AY 2020-2021

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Amey Madhav Baitule Ito, Ward – 3(1), Kalyan 01 Plot No. Rm 25, Kasturi Shilp, Vs Rani Mansion, Kalyan, Kalyan- Milap Nagar, Midc Residential Dombivali, Maharashtra – 421301. Zone, Dombivali, Thane, Maharashtra – 421203. [Pan: Bbupb5254K] Appellant / Assessee Respondent / Revenue Assessee By Shri Sanjiv Brahme, Ca Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 18.05.2026 Date Of Pronouncement 17.08.2026 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh; 1. This Appeal By Assessee Is Directed Against The Order Of Ld. Cit(A)/ Nfacdated 28.10.2025 For Assessment Year (Ay) 2020-21. The Assessee Has Raised Following Grounds Of Appeal: “1. The Cit (Appeal) Has Failed To Consider The Legal Point Raised By The Appellant That Notice U/S.148 Was Bad-In-Law & Has Been Done Mechanically. 2. The Cit (Appeal) Has Erred In Ignoring Our Point With Regards To Approval By Prcit. 3. The Cit (Appeal) Has Failed To Consider The Contention Of The Appellant That The Notice U/S 148 Is Bad In Law Since The Assessing Officer Has Not Received Any Fresh Material & He Had Earlier Issued Notice For Ay 2019-20, Which He Had Dropped 4. The Notice U/S 148 Is Bad In Law As The Approval Was Given By Prcit, Mechanically. Prcit-1 Has Given Earlier Approval For Previous Assessment Year 2019-20 & After Being Pointing Out The Flaws, The Assessing Officer Amey Madhav Baitule

Section 115JSection 143Section 143(2)Section 147Section 148Section 151Section 254(1)Section 271ASection 69

M/S. Lucas Indian Service Ltd., Chennai vs. DCIT, Corp. Cirlce-4(1), Chennai

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

ITA 1132/CHNY/2026[2020-21]Status: DisposedITAT Chennai13 Aug 2026AY 2020-21

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपीलसं./Ita Nos.1131 & 1132/Chny/2026 (ननिाारण वर्ा / Assessment Year:2018-19 & 2020-21) M/S.Lucas Indian Service Limited The Deputy Commissioner Of No.28, Poomagal Main Road Vs. Income-Tax Behind Olympia Tech Park Corporate Circle 4(1) Ekkattuthangal, Chennai. Chennai – 600 032. [Pan:Aaacl1018J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. S.P.Chidambaram, Advocate प्रत्यथी की ओर से/Respondent By : Ms. Anshu Sharawat, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 13.07.2026 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2026 आदेश / O R D E R Per S.R.Raghunatha, Am: These Two Appeals Filed By The Assessee Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year (Ay) 2018-19 & Ay 2020-21, Vide Order Dated 10.12.2025 & 10.12.2025 Respectively Against The Assessment Orders Passed By Assessment Unit, Nfac, Delhi, (In Short “The Ao”) U/S.143(3) Of The Income Tax Act, 1961 (In Short “The Act”) Dated 10.02.2021 &

For Appellant: Shri. S.P.Chidambaram, AdvocateFor Respondent: Ms. Anshu Sharawat, Addl. CIT
Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)

M/S. Lucas Indian Service Ltd., Chennai vs. DCIT, Corporate Circle-4(1), Chennai

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

ITA 1131/CHNY/2026[2018-19]Status: DisposedITAT Chennai13 Aug 2026AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपीलसं./Ita Nos.1131 & 1132/Chny/2026 (ननिाारण वर्ा / Assessment Year:2018-19 & 2020-21) M/S.Lucas Indian Service Limited The Deputy Commissioner Of No.28, Poomagal Main Road Vs. Income-Tax Behind Olympia Tech Park Corporate Circle 4(1) Ekkattuthangal, Chennai. Chennai – 600 032. [Pan:Aaacl1018J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. S.P.Chidambaram, Advocate प्रत्यथी की ओर से/Respondent By : Ms. Anshu Sharawat, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 13.07.2026 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2026 आदेश / O R D E R Per S.R.Raghunatha, Am: These Two Appeals Filed By The Assessee Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year (Ay) 2018-19 & Ay 2020-21, Vide Order Dated 10.12.2025 & 10.12.2025 Respectively Against The Assessment Orders Passed By Assessment Unit, Nfac, Delhi, (In Short “The Ao”) U/S.143(3) Of The Income Tax Act, 1961 (In Short “The Act”) Dated 10.02.2021 &

For Appellant: Shri. S.P.Chidambaram, AdvocateFor Respondent: Ms. Anshu Sharawat, Addl. CIT
Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)