Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
MAT book-profit computation under section 115JB does not permit...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory computation rules.
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MAT book-profit computation under section 115JB does not permit adding back expenditure disallowed under section 14A merely because it relates to exempt income. The Special Bench ruling in Vireet Investment establishes that section 14A disallowance is not an adjustment to book profit. Explanation 1 to section 115JB(2) exhaustively specifies permissible additions and does not include demerger expenditure disallowed under section 35DD in the regular tax computation. Consequently, neither the section 14A disallowance nor the section 35DD disallowance is added back while computing MAT book profit.
MAT book-profit computation under section 115JB does not permit adding back expenditure disallowed under section 14A merely because it relates to exempt income. The Special Bench ruling in Vireet Investment establishes that section 14A disallowance is not an adjustment to book profit. Explanation 1 to section 115JB(2) exhaustively specifies permissible additions and does not include demerger expenditure disallowed under section 35DD in the regular tax computation. Consequently, neither the section 14A disallowance nor the section 35DD disallowance is added back while computing MAT book profit.
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