Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Rule 8AB - Attribution of income taxable under sub-section (4) of section 45 to the capital assets remaining with the specified entity, under section 48
Income-tax Rules, 1962 Part D Special cases
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Attribution of income to retained capital assets clarifies allocation, reporting and valuation-based carve-outs under tax rule. Where income charged as income of a specified entity under sub-section (4) of section 45 relates to revaluation or valuation of self-generated asset or goodwill, the amount attributed to each capital asset remaining with the specified entity shall be apportioned in the same proportion as the increase or recognition in value of that asset bears to the aggregate increase or recognition across all such assets; if it does not relate to such revaluation or valuation, or relates only to the asset transferred, no attribution to retained assets is required. The specified entity must report attributed amounts in Form No. 5C, filed electronically and verified as prescribed.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Attribution of income to retained capital assets clarifies allocation, reporting and valuation-based carve-outs under tax rule.
Where income charged as income of a specified entity under sub-section (4) of section 45 relates to revaluation or valuation of self-generated asset or goodwill, the amount attributed to each capital asset remaining with the specified entity shall be apportioned in the same proportion as the increase or recognition in value of that asset bears to the aggregate increase or recognition across all such assets; if it does not relate to such revaluation or valuation, or relates only to the asset transferred, no attribution to retained assets is required. The specified entity must report attributed amounts in Form No. 5C, filed electronically and verified as prescribed.
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