Concessional tax conditions restrict deductions and set eligibility rules for companies claiming reduced corporate tax treatment. The provision conditions access to a concessional tax regime by specifying that total income must be computed without deductions under listed sections, and by imposing eligibility requirements: no formation by simple split/reconstruction except narrow re establishment, strict limits on previously used machinery or plant (with permitted overseas machinery exceptions), prohibition for domestic companies on using buildings earlier claimed for a specified investment deduction as hotels or convention centres, and confinement to manufacture or production (including electricity generation) with enumerated exclusions. The Board may issue time limited guidelines with governmental approval, and the Assessing Officer may adjust profits and apply arm's length pricing for related party excess profits.
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Provisions expressly mentioned in the judgment/order text.
Concessional tax conditions restrict deductions and set eligibility rules for companies claiming reduced corporate tax treatment.
The provision conditions access to a concessional tax regime by specifying that total income must be computed without deductions under listed sections, and by imposing eligibility requirements: no formation by simple split/reconstruction except narrow re establishment, strict limits on previously used machinery or plant (with permitted overseas machinery exceptions), prohibition for domestic companies on using buildings earlier claimed for a specified investment deduction as hotels or convention centres, and confinement to manufacture or production (including electricity generation) with enumerated exclusions. The Board may issue time limited guidelines with governmental approval, and the Assessing Officer may adjust profits and apply arm's length pricing for related party excess profits.
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