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Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2025 (7) TMI AT This

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2025 (7) TMI 1381 - AT - Income Tax


The Appellate Tribunal (ITAT Mumbai) dismissed the Revenue's appeal against the order of the Learned Commissioner of Income-tax (CIT(A)) for AY 2021-22 concerning the adjustment of Minimum Alternate Tax (MAT) credit. The Revenue challenged the CIT(A)'s allowance of MAT credit of Rs. 29,94,40,364/-, which exceeded the MAT credit of Rs. 29,17,19,510/- claimed in the original return, seeking condonation of delay to file a revised return. The assessee had filed the return under section 139(1) and the return was processed under section 143(1), where additions under sections 35(1)(i) and 41 were confirmed. The CIT(A) deleted these additions and directed recomputation of MAT credit in the Order Giving Effect (OGE). The Revenue's challenge was limited to the MAT credit adjustment, which was "purely consequential in nature" following the deletion of additions, and did not contest the deletion itself. The Tribunal noted no substantial objection from the Departmental Representative and held there was "no infirmity in the order of the Ld. CIT(A)." Accordingly, the appeal was dismissed. The decision underscores that MAT credit adjustments flowing from appellate deletion of additions are consequential and not independently contestable where the underlying additions are not challenged.

 

 

 

 

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