Topic
ITAT Delhi rules that disallowance under Section 14A read with Rule 8D cannot be factored into book profit computation for MAT under Section 115JB. The ruling clarifies that such disallowances remain excluded from MAT calculations, impacting corporate tax assessments.
ITAT Delhi rules that government grants received under the Focus Product Scheme qualify as capital receipts, exempting them from Minimum Alternate Tax (MAT) under Section 115JB. The decision clarifies the tax treatment of export incentives, impacting corporate tax planning and compliance for businesses availing such schemes.
The ITAT Bangalore ruled that public sector banks can claim CSR spending and 60% depreciation on ATMs as allowable business expenses under Section 36(1)(viii), thereby excluding them from Section 115JB book profit tax. This sets a critical precedent for the banking sector, affirming that regulatory compliance costs and infrastructure investments essential to modern banking operations qualify as genuine business expenditures, not disallowable non-business outlays.
ITAT Ahmedabad rules that Corporate Social Responsibility (CSR) expenses cannot be added back to 'book profit' for Minimum Alternate Tax (MAT) calculations under Section 115JB. The tribunal also clarifies that Section 14A disallowance for exempt income does not apply when tax liability is computed under MAT, offering relief to taxpayers facing revisionary proceedings.
ITAT Ahmedabad rules that warranty provisions calculated through past experience and scientific estimation qualify as ascertained liabilities under Section 115JB, barring their addition to book profits. This clarifies the tax treatment of contingent liabilities for corporate taxpayers, ensuring compliance with accounting standards while preventing double taxation.