🚨 Important Update for Our Users
We are transitioning to our new and improved portal - www.taxtmi.com - for a better experience.
⚠️ This portal will be fully migrated on 31-July-2025 at 23:59:59
After this date, all services will be available exclusively on our new platform.
If you encounter any issues or problems while using the new portal,
please let us know
via our feedback form
, with specific details, so we can address them promptly.
Home
2025 (7) TMI 1381 - AT - Income TaxAdjustment of MAT credit u/s 115JAA - CIT(A) directed the AO to adjust the MAT credit in the re-computation on giving effect to appellate order - HELD THAT - It is evident that the said adjustment is purely consequential in nature arising from the deletion of additions in appeal. Notably the revenue has not contested the deletion of additions made u/s 35(1) and 41 of the Act in its grounds of appeal. DR did not raise any substantial objection to the observations of the Bench. 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.
|