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High Court affirms disallowance deduction method for MAT assessment under IT Act The High Court of Madras upheld the decision regarding the calculation of disallowance deduction under s. 80HHC in a case of MAT assessment based on the ...
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High Court affirms disallowance deduction method for MAT assessment under IT Act
The High Court of Madras upheld the decision regarding the calculation of disallowance deduction under s. 80HHC in a case of MAT assessment based on the adjusted book profit under s. 115JB of the IT Act, 1961, following its previous ruling and established Supreme Court precedents. The Court dismissed the tax case appeals filed by the Revenue, citing consistency with its prior decision and reliance on Supreme Court precedents.
Issues involved: Interpretation of deduction under s. 80HHC in a case of MAT assessment based on adjusted book profit under s. 115JB of the IT Act, 1961.
Summary:
Interpretation of deduction under s. 80HHC in MAT assessment: The tax case appeals were filed by the Revenue questioning the validity of the Tribunal's decision regarding the disallowance deduction under s. 80HHC in a case of MAT assessment to be calculated based on the adjusted book profit under s. 115JB of the IT Act, 1961. The learned counsel for the Revenue argued that a similar issue had been addressed by the Court previously in CIT vs. Rajanikant Schnelder & Associates (P) Ltd. (2008) 302 ITR 22(Mad). Despite a different view taken by the Bombay High Court in CIT vs. Ajanta Pharma Ltd. (2009) 223 CTR (Bom), the Court upheld its previous decision in Rajanikant Schnelder & Associates (P) Ltd. case, citing the precedents set by the Supreme Court in Surana Steels (P) Ltd. vs. Dy. CIT (1999) 237 ITR 777(SC) and Apollo Tyres Ltd. vs. CIT ((2002) 255 ITR 273(SC). The Court deemed its own decision in 2007 as binding, and consequently dismissed the tax case appeals filed by the Revenue.
Conclusion: The High Court of Madras upheld the decision regarding the calculation of disallowance deduction under s. 80HHC in a case of MAT assessment based on the adjusted book profit under s. 115JB of the IT Act, 1961, following its previous ruling and established Supreme Court precedents.
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