MAT computation excludes Section 14A disallowance; exempt-income expenditure must be determined independently under book profit rules.

Section 14A read with Rule 8D cannot be imported into computation of book profit under section 115JB because MAT operates as a self-contained code. Expenditure relatable to exempt income must instead be determined independently under clause (f) of Explanation 1 to section 115JB. On that basis, the addition made by applying section 14A while computing book profit was held unsustainable, and the matter was remitted for fresh computation under section 115JB.

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Issues: Whether disallowance computed under section 14A read with Rule 8D could be added back while computing book profit under section 115JB.

Analysis: The Tribunal followed the jurisdictional High Court and the Special Bench decision holding that section 115JB is a self-contained code for computation of book profit. The expenditure relatable to exempt income has to be determined independently under clause (f) of Explanation 1 to section 115JB, and the mechanism under section 14A or Rule 8D cannot be imported into MAT computation.

Conclusion: The addition made by applying section 14A while computing book profit under section 115JB was not sustainable. The matter was restored to the Assessing Officer to recompute the expenditure relatable to exempt income independently under section 115JB.

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