Depreciation deduction treatment: carryover of prior depreciation where qualifying intra group or amalgamation transfers occur. Where a capital asset is transferred between a holding company and its subsidiary, or between companies in a scheme of amalgamation, and the conditions for tax neutral reorganisation under section 47 are satisfied, the aggregate deduction for depreciation must include the depreciation allowances allowed to the company from which the asset was transferred.
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Provisions expressly mentioned in the judgment/order text.
Depreciation deduction treatment: carryover of prior depreciation where qualifying intra group or amalgamation transfers occur.
Where a capital asset is transferred between a holding company and its subsidiary, or between companies in a scheme of amalgamation, and the conditions for tax neutral reorganisation under section 47 are satisfied, the aggregate deduction for depreciation must include the depreciation allowances allowed to the company from which the asset was transferred.
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