Section 115BAA excludes MAT under section 115JB for opted companies, confirming concessional tax treatment and consistency.

A company that validly exercises the concessional corporate tax option under section 115BAA is outside the scope of MAT under section 115JB because section 115JB(5A) expressly excludes its application. On that basis, an adjustment made by computing book profit and tax liability under section 115JB was not sustainable. The note also reflects the principle of consistency, since the same treatment had already been accepted in earlier assessment years, reinforcing the exclusion of MAT for the taxpayer after opting for section 115BAA.

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Issues: Whether, after exercise of the option under section 115BAA of the Income-tax Act, 1961, the provisions of section 115JB could still be applied for computing book profit and tax liability.

Analysis: The option under section 115BAA was treated as valid and as having already been accepted in earlier assessment years. The statutory scheme of section 115JB(5A) excludes the applicability of Minimum Alternate Tax to a company that has exercised the option under section 115BAA. In view of that legislative exclusion, and also on the principle of consistency since the same processing had been accepted for earlier years, the adjustment made by applying section 115JB was not sustainable.

Conclusion: Section 115JB was held inapplicable once the assessee had exercised the option under section 115BAA, and the relief granted to the assessee was upheld.

Final Conclusion: The assessee's computation under the concessional corporate tax regime was sustained and the Revenue's challenge to the deletion of the MAT adjustment failed.

Ratio Decidendi: A company that has validly exercised the option under section 115BAA is outside the ambit of section 115JB by virtue of section 115JB(5A), so MAT cannot be invoked against it.

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