Minimum Alternate Tax credit reduction: declarant may include the reduction in disputed tax or carry forward the reduced credit. A declarant facing a reduction in MAT credit may either include the reduction amount in disputed tax and carry forward MAT credit unchanged, or carry forward the reduced credit. Electing to carry forward the reduced credit triggers liability for tax, surcharge, cess and interest arising from that carry forward. For non-eligible-search cases where reduction stems from issues decided for the declarant, one-half of the reduction is considered for carry-forward computation. For eligible search cases, one and one-fourth times the reduction is considered (capped at pre-reduction credit), and an additional proviso provides that five-eighths of the reduction is to be considered where reductions relate to issues decided in the declarant's favour. 'MAT credit' means credit under sections 115JAA or 115JD.
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Provisions expressly mentioned in the judgment/order text.
Minimum Alternate Tax credit reduction: declarant may include the reduction in disputed tax or carry forward the reduced credit.
A declarant facing a reduction in MAT credit may either include the reduction amount in disputed tax and carry forward MAT credit unchanged, or carry forward the reduced credit. Electing to carry forward the reduced credit triggers liability for tax, surcharge, cess and interest arising from that carry forward. For non-eligible-search cases where reduction stems from issues decided for the declarant, one-half of the reduction is considered for carry-forward computation. For eligible search cases, one and one-fourth times the reduction is considered (capped at pre-reduction credit), and an additional proviso provides that five-eighths of the reduction is to be considered where reductions relate to issues decided in the declarant's favour. "MAT credit" means credit under sections 115JAA or 115JD.
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