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)
CBDT issues second round of frequently asked questions in relation to Direct Tax Vivad Se Vishwas Scheme, 2024
This Tax Alert summarizes Circular No. 19/2024 dated 16 December 2024 (VSV 2- December Circular) issued by the Central Board of Direct Tax...
-
PCIT vs. The Executor of Estate of Late Smt. Manjula A. Shah (Bombay High Court) S. 50C Capital Gains: The valuation of the stamp autho...
-
This Tax Alert summarizes a recent ruling of the Supreme Court (SC) [1] on availability of CENVAT Credit on mobile towers and pre-fabrica...
-
IFRS and US GAAP - Similarities and Differences What is IFRS? And what is GAAP? The main difference between IFRS and US GAAP is that G...
-
Madras HC reverses ITAT's order, grants deduction u/s. 80P(2)(a)(i) to assessee (a society engaged in the business of banking and provi...
-
SC dismisses assessee-company’s SLP challenging Bombay HC order upholding re-assessment initiation (beyond 4 yrs period) based on a special...
-
SC dismisses Revenue’s SLP challenging Bombay HC order in case of assessee (belonging to Lodha group of companies engaged in real estate bu...
-
Claiming a foreign tax credit (FTC) in Australia allows companies to offset foreign taxes paid on income earned overseas against their Aust...
-
HC allows HDFC Bank’s writ petition, quashes AO’s order and subsequent reference to TPO alleging that certain related party transactions [p...
-
Delhi ITAT deletes Rs. 1558.57 cr. capital gains addition on Telenor India for AY 2014-15, holds that set off of non-refundable entry fee p...
-
This Tax Alert summarizes a recent ruling of the Bombay High Court (HC)1 on admissibility of input tax credit (ITC) w.r.t GST on advance p...
No comments:
Post a Comment