Capital allowance allocation pro rata between predecessor and successor upon intra year business reorganisation under section 35 framework.

When business reorganisation occurs during a financial year, the capital allowance deduction referred to in section 35 is apportioned pro rata: the predecessor's share equals the full-year deduction multiplied by the days from the first day of the financial year to the day before reorganisation divided by total days in the year; the successor's share equals the full-year deduction multiplied by the days from the date of reorganisation to the last day of the financial year divided by total days in the year.

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