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Debatable MAT Loss Adjustment Can’t Be Rectified U/s 154: ITAT Quashes Rs. 40.68 Crore Demand Against Fiat India

03/02/2026

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The Pune Bench of the Income Tax Appellate Tribunal (ITAT) has quashed a Rs. 40.68 crore tax demand raised against Fiat India Automobiles Pvt. Ltd., holding that adjustments relating to brought-forward losses and unabsorbed depreciation while computing book profits under Section 115JB (MAT provisions) involve debatable issues and cannot be reopened through rectification proceedings under…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 5+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started as a freelance tax reporter in the leading online legal news companies like LiveLaw & Taxscan.

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Debatable MAT Loss Adjustment Can’t Be Rectified U/s 154: ITAT Quashes Rs. 40.68 Crore Demand Against Fiat India

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Debatable MAT Loss Adjustment Can’t Be Rectified U/s 154: ITAT Quashes Rs. 40.68 Crore Demand Against Fiat India

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