https://www.taxtmi.com/caselaws?id=783241 ITAT Kolkata allowed the assessee's appeal, holding that the AO could not invoke s.154 to rectify the assessment by adding disallowance computed u/s 14A to book profits u/s 115JB. The Tribunal held that whether s.14A read with Rule 8D applies to MAT computation under s.115JB is a debatable issue on which more than one view is possible, and thus not a "mistake apparent from the record." On merits as well, following prevailing jurisprudence, it held that disallowance u/s 14A cannot be imported into the s.115JB computation, and the assessee was entitled to full relief. en-us Thu, 27 Nov 2025 00:00:00 +0530 Fri, 12 Dec 2025 08:55:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783241 ITAT Kolkata allowed the assessee's appeal, holding that the AO could not invoke s.154 to rectify the assessment by adding disallowance computed u/s 14A to book profits u/s 115JB. The Tribunal held that whether s.14A read with Rule 8D applies to MAT computation under s.115JB is a debatable issue on which more than one view is possible, and thus not a "mistake apparent from the record." On merits as well, following prevailing jurisprudence, it held that disallowance u/s 14A cannot be imported into the s.115JB computation, and the assessee was entitled to full relief. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783241