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of <h1>Tax rules for first-year Indian-resident foreign companies: applicability, recovery, anti-avoidance, recomputation and section 154 four-year limit</h1> When a foreign company is treated as resident in India for a previous year and was non-resident in all preceding years, income-tax provisions on computing total income, treatment of unabsorbed depreciation and losses, collection and recovery, and anti-avoidance may be made applicable for that year subject to conditions notified by the Central Government; if residency is determined in assessment, those rules can also apply to subsequent relevant years. If conditions of the notification are later not complied with, any granted benefits are treated as wrongly allowed, the Assessing Officer may recompute income as if exceptions did not apply, and amendments follow section 154 with a four-year limitation. Notifications must be laid before Parliament.
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