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ITAT determined MAT provisions under s.115JB were inapplicable to electricity companies governed by specific statutes before the 2013 amendment, regardless of incorporation status. Following Raj. HC precedent in Ajmer Vidyut case, the tribunal rejected CIT(A)'s interpretation that excluded only power generation companies under s.115JA(iv). The legislative history confirmed electricity companies were not intended for MAT coverage pre-2012. The tribunal allowed the assessee's appeals, deleting additions to book profits under s.115JB for both assessment years, emphasizing that companies operating under distinct electricity statutes remained outside MAT's scope until the specific amendment effective April 1, 2013.
ITAT determined MAT provisions under s.115JB were inapplicable to electricity companies governed by specific statutes before the 2013 amendment, regardless of incorporation status. Following Raj. HC precedent in Ajmer Vidyut case, the tribunal rejected CIT(A)'s interpretation that excluded only power generation companies under s.115JA(iv). The legislative history confirmed electricity companies were not intended for MAT coverage pre-2012. The tribunal allowed the assessee's appeals, deleting additions to book profits under s.115JB for both assessment years, emphasizing that companies operating under distinct electricity statutes remained outside MAT's scope until the specific amendment effective April 1, 2013.
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