MAT credit entitlement upheld where normal tax exceeded MAT liability and rectification could not justify denial.

MAT credit under section 115JAA was considered available where the assessee's normal tax liability exceeded the MAT liability, and the return processing had omitted the set-off claim. The rectification under section 154 was found to provide no legally sustainable basis for denying the credit. On that basis, the assessee was held entitled to MAT credit against the tax liability for the assessment year 2021-22, and the denial of the credit was held unsustainable.

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Issues: Whether the assessee was entitled to MAT credit of Rs. 1,17,383 against the tax liability for the assessment year 2021-22 and whether the denial of such credit was unsustainable.

Analysis: The assessee had claimed set-off of accumulated MAT credit against the excess tax liability arising under the normal provisions over the MAT liability. The return processing under section 143(1) of the Income-tax Act, 1961 had overlooked the claim, and the rectification proceedings under section 154 of the Income-tax Act, 1961 did not furnish any legally sustainable basis for denial. The entitlement to MAT credit under section 115JAA of the Income-tax Act, 1961 was found to follow from the excess of normal tax over MAT liability.

Conclusion: The assessee was held entitled to MAT credit of Rs. 1,17,383, and the denial of credit was held unsustainable.

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