CBDT issues draft
notification u/s. 115JG(1) specifying the conditions to be fulfilled upon
conversion of Indian Branch of foreign bank into Indian subsidiary
company and also specifying modifications, exceptions, in applicability
of certain provisions of the Act to such conversion; Draft notification
proposes following conditions, viz. (a) all the assets and liabilities of the
Indian branch immediately before conversion become the assets and liabilities
of the Indian subsidiary Company, (b) the foreign company (engaged in banking
business in India through branch) or its nominees hold the whole of the
share capital of the subsidiary company and (c) the foreign company does not
receive any consideration or benefit, other than by way of allotment of shares in
the Indian subsidiary company; With respect to unabsorbed depreciation,
draft notification proposes that the aggregate depreciation deduction allowable
to the Indian branch and the Indian subsidiary company shall not exceed the
deduction calculated at the prescribed rates as if the conversion had not taken
place, and such deduction to be apportioned between the Indian branch and
the Indian subsidiary company in the ratio of the number of days for which the
assets were used by them; Further, it proposes that the tax credit of the
Indian branch shall be deemed to be the tax credit of the Indian subsidiary
company for the purpose of the previous year in which conversion was effected
and the provisions of Sec. 115JAA shall apply accordingly; Invites stakeholders
comments/suggestions on the draft notification by November 30th
Subscribe to:
Post Comments (Atom)
Kolkata ITAT holds Husband's HUF not falling in the definition of ‘Relative’ of a Wife for gift-tax purposes under Income-tax
Kolkata Tribunal has recently ruled that HUFs cannot be treated as “relatives” under the gift-tax provisions of the Income-tax Act, thereb...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
Introduction: ADR’S, GDR’S: These are commonly known as Depository Receipts (‘DR’), a negotiable security issued outside India by a deposi...
-
In the case of "Maya Gopinathan vs Anoop SB 2024 INSC 334," the Hon'ble Supreme Court provided insightful guidance on the de...
-
Particulars in Part 1 and Part 2 of Step-2 of registration form are required to be exactly the same as reported in the TDS statement. Plea...
-
An eminent concern within the GST framework pertains to the entitlement of Input Tax Credit (ITC) concerning expenditures associated with In...
-
In Standard Castings Private Limited v. ITO , the Hon’ble ITAT Delhi allowed the assessee’s appeal and set aside a demand that had continu...
-
Introduction Employee welfare is a cornerstone of corporate responsibility, and gratuity forms a critical part of the social security benefi...
-
The Approving Panel under General Anti-Avoidance Rules (GAAR), in a landmark direction, has characterized the demerger of Digital, Media a...
-
Section 68 -Cash credits Section 69 -Unexplained investments Section 69A - Unexplained money, etc Section 69B -Amount of investme...
-
Key Notes: Transfer pricing relates to the pricing of transactions (such as transfer of goods, services, intangibles and funds) that t...
No comments:
Post a Comment