Deduction on intercorporate dividends reduces corporate tax where companies receive dividends from Indian companies, with lower threshold for specified industries. Section 85A permits a company whose total income includes dividends from an Indian company (or a company with prescribed dividend arrangements within India) to deduct from its income tax that portion of tax, computed at the average rate on such included dividend income (excluding exempt dividends), which exceeds a prescribed base percentage. A lower base percentage applies where the recipient lacks the prescribed arrangements and the dividend-paying Indian company is mainly engaged in electricity generation/distribution or certain specified manufacturing activities; 'mainly engaged' is defined by at least fifty-one percent of income from those activities.
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Provisions expressly mentioned in the judgment/order text.
Deduction on intercorporate dividends reduces corporate tax where companies receive dividends from Indian companies, with lower threshold for specified industries.
Section 85A permits a company whose total income includes dividends from an Indian company (or a company with prescribed dividend arrangements within India) to deduct from its income tax that portion of tax, computed at the average rate on such included dividend income (excluding exempt dividends), which exceeds a prescribed base percentage. A lower base percentage applies where the recipient lacks the prescribed arrangements and the dividend-paying Indian company is mainly engaged in electricity generation/distribution or certain specified manufacturing activities; "mainly engaged" is defined by at least fifty-one percent of income from those activities.
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