Section 115JB book profit computation remains independent of section 14A disallowance under the Vireet Investment principle.

Disallowance under section 14A was considered not to govern computation of book profits under section 115JB, because the Tribunal applied the Special Bench ruling in Vireet Investment Pvt. Ltd. to treat section 115JB as an independent mechanism for determining book profit. On that basis, the Tribunal held that the Revenue's objection did not show any error in the earlier order that had granted relief to the assessee, and the rectification request was rejected.

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Issues: Whether disallowance under section 14A could be adopted while computing book profits under section 115JB and whether the Tribunal's earlier order warranted rectification.

Analysis: The Tribunal noted that the issue was governed by the Special Bench decision in Vireet Investment Pvt. Ltd., which held that computation under section 115JB is an independent mechanism for determining book profits. The Tribunal accepted that the Revenue's objection did not displace the view already taken and found no error in the earlier order that had granted relief to the assessee.

Conclusion: The misc. petition was rejected and the Revenue's challenge to the earlier order failed.

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