MAT credit computation requires fresh verification after appellate effect before rectification of the income-tax order.

Carry-forward and set-off of MAT credit under section 115JAA required fresh verification because the availability of credit for earlier assessment years had not been examined after giving effect to prior appellate orders. In the absence of such computation, the correctness of the rectification under section 154 could not be properly determined. The matter was therefore remanded to the Assessing Officer to recompute the actual MAT credit available in earlier years after implementing the appellate orders, and the rectification order was not finally sustained.

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Issues: Whether the order under section 154 of the Income-tax Act, 1961 confirming the reduction of minimum alternate tax credit was sustainable and whether the matter required remand to recompute the available MAT credit after giving effect to earlier appellate orders.

Analysis: The dispute centered on the assessee's entitlement to carry forward and set off MAT credit under section 115JAA of the Income-tax Act, 1961. The record showed that the availability of credit for the earlier assessment years had not been examined after giving appeal effect to the Tribunal and the appellate authority's orders. Without such examination, the correctness of the rectification order could not be properly determined. The Tribunal therefore found it appropriate to direct a fresh consideration by the Assessing Officer so that the actual MAT credit available in earlier years could be computed after giving effect to the appellate orders.

Conclusion: The rectification order was not finally sustained and the matter was remanded to the Assessing Officer for fresh computation of MAT credit. The appeal was allowed for statistical purposes.

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