M.J. Exports (P.) Ltd. v. JCIT [2025] 176 taxmann.com 342 (Bom) (HC)

S. 115JA : Company-Book profit-Minimum alternate tax-Provision for doubtful debts-Amount receivable-Not a liability or reserve-Addition to book profit not permissible.[S.260A]

 

Where the assessee created a provision for doubtful debts/advances in respect of an amount receivable from a US-based customer, the High Court held that the amount represented a debt receivable by the assessee and was therefore an asset and not a liability; consequently, it could not be added to book profit under clause (c) of the Explanation to section 115JA as an unascertained liability or treated as a “reserve” under clause (b), and clause (g), inserted with effect from 1-4-1998, had no application to assessment year 1997-98. The additions to book profit were accordingly set aside. (AY. 1997-98).

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