https://www.taxtmi.com/caselaws?id=465255 ITAT Delhi (AT) dismissed the Revenue's appeal against the deletion of disallowance made u/s 14A r/w Rule 8D while computing book profit u/s 115JB in the case of a resident company. The AO had invoked s. 154, based solely on Revenue audit objection, to enhance book profit by applying s. 14A to MAT computation. ITAT held that the applicability of s. 14A r/w Rule 8D to s. 115JB is a highly debatable issue and cannot constitute a "mistake apparent from record" under s. 154. Relying on the Special Bench ruling in Vireet Investment, the disallowance was held impermissible. en-us Tue, 31 May 2022 00:00:00 +0530 Fri, 12 Dec 2025 20:19:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465255 ITAT Delhi (AT) dismissed the Revenue's appeal against the deletion of disallowance made u/s 14A r/w Rule 8D while computing book profit u/s 115JB in the case of a resident company. The AO had invoked s. 154, based solely on Revenue audit objection, to enhance book profit by applying s. 14A to MAT computation. ITAT held that the applicability of s. 14A r/w Rule 8D to s. 115JB is a highly debatable issue and cannot constitute a "mistake apparent from record" under s. 154. Relying on the Special Bench ruling in Vireet Investment, the disallowance was held impermissible. Case-Laws Income Tax Tue, 31 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465255