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HC ruled against levying interest u/s 234B for additions made to book profit under MAT provisions. Court emphasized that multiple Coordinate Benches previously established that interest cannot be charged when retrospective amendments to Section 115JB's explanation (via Finance Act 2008) result in book profit adjustments. Court criticized revenue authorities for failing to disclose binding precedents from previous cases involving similar issues. While acknowledging taxation matters exclude equity considerations, HC stressed revenue's obligation for transparency in legal proceedings. Appeal was dismissed, upholding that retrospective inclusion of items in book profit computation does not warrant Section 234B interest charges.
HC ruled against levying interest u/s 234B for additions made to book profit under MAT provisions. Court emphasized that multiple Coordinate Benches previously established that interest cannot be charged when retrospective amendments to Section 115JB's explanation (via Finance Act 2008) result in book profit adjustments. Court criticized revenue authorities for failing to disclose binding precedents from previous cases involving similar issues. While acknowledging taxation matters exclude equity considerations, HC stressed revenue's obligation for transparency in legal proceedings. Appeal was dismissed, upholding that retrospective inclusion of items in book profit computation does not warrant Section 234B interest charges.
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