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The ITAT considered a rectification order u/s 154 regarding MAT computation u/s 115JB on profit from the sale of agricultural land exempt from income tax. The Assessing Officer accepted the income initially but later raised the taxability issue under rectification. The Tribunal held that such profit, not a capital asset under normal provisions, cannot be taxed under MAT. Citing precedents, including HARRISONS MALAYALAM LTD. and others, it ruled that if AO did not treat the gain for book profit, the issue cannot be raised. Exempt income from agricultural land cannot be added to book profit for MAT calculation u/s 115JB. Decision favored the assessee.
The ITAT considered a rectification order u/s 154 regarding MAT computation u/s 115JB on profit from the sale of agricultural land exempt from income tax. The Assessing Officer accepted the income initially but later raised the taxability issue under rectification. The Tribunal held that such profit, not a capital asset under normal provisions, cannot be taxed under MAT. Citing precedents, including HARRISONS MALAYALAM LTD. and others, it ruled that if AO did not treat the gain for book profit, the issue cannot be raised. Exempt income from agricultural land cannot be added to book profit for MAT calculation u/s 115JB. Decision favored the assessee.
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