S.R. Ingots (P.) Ltd. v. ACIT (2025) 210 ITD 254 (Raipur) (Trib.)

S. 115J : Company-Book profit-Adjustment-Exempt income-Matter remanded.[S. 14A, R.8D]

Held that disallowance under section 14A read with rule 8D could not be added while computing book profit under section 115JB,  however, adjustment qua expenditure directly incurred towards generating exempt income could be made for computing book profit under section 115JB as per clause (f) of Explanation 1 to section 115JB(2), without resorting to amount calculated under section 14A read with rule 8D.  Matter is remanded back to Assessing Officer for fresh adjudication.  (AY. 2012-13, 2013-14)

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