Minimum alternate tax does not apply to statutory bodies outside the Companies Act, leaving book-profit disallowance challenge unsustainable.

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....Minimum Alternate Tax under section 115JB does not apply to a statutory body constituted under a Central enactment that is not incorporated under the Companies Act, despite being assessable as a company under the Income-tax Act. Applying the principle that the legal fiction in section 115JB cannot extend to such entities, the High Court found the provision inapplicable. Consequently, the issue of disallowance under section 14A in computing book profit did not survive, as it depended on section 115JB applying. No substantial question of law arose, and the Revenue's appeals were dismissed.....