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The Tax Publishers Manipal Technologies Ltd. v. Addl. CIT [ITA No. 633/Bang/2014, dt. 29-4-2016] : 2016 TaxPub(DT) 2931 (Bang-Trib) Section 14A disallowance whether can be added back for MAT provisions *Facts:* Assessee in the business of printing and sale of books had disallowance under section 14A which was added back while arriving at MAT liability. Commissioner (Appeals) did not consider the appeal of the assessee on this point. On further appeal: Held in favour of the assessee that section 14A provisions cannot be inducted/telescoped into MAT provisions. Reliance Industrial Infrastructure Ltd. v Addl.CIT in ITA Nos.69 & 70/Mum/2009 dated 5-4-2013 wherein, by following the decision of the Delhi Bench of the Tribunal in the case of Goetze (India) Ltd, it was held that while computation of adjusted book profits, the provisions of section 14A cannot be imported into clause (f) of the Explanation to section 115JB of the Act.

The Tax Publishers

Manipal Technologies Ltd. v. Addl. CIT [ITA No. 633/Bang/2014, dt. 29-4-2016] : 2016 TaxPub(DT) 2931 (Bang-Trib)

Section 14A disallowance whether can be added back for MAT provisions

Facts:

Assessee in the business of printing and sale of books had disallowance under section 14A which was added back while arriving at MAT liability. Commissioner (Appeals) did not consider the appeal of the assessee on this point. On further appeal:

Held in favour of the assessee that section 14A provisions cannot be inducted/telescoped into MAT provisions.

Reliance Industrial Infrastructure Ltd. v Addl.CIT in ITA Nos.69 & 70/Mum/2009 dated 5-4-2013 wherein, by following the decision of the Delhi Bench of the Tribunal in the case of Goetze (India) Ltd, it was held that while computation of adjusted book profits, the provisions of section 14A cannot be imported into clause (f) of the Explanation to section 115JB of the Act.