Branch conversion tax neutrality: capital gains relief and entitlement to carry forward losses subject to notified conditions. Conversion of an Indian branch of a foreign banking company into an Indian subsidiary yields tax neutrality: capital gains on conversion are exempt and provisions on carry forward/set off of losses, unabsorbed depreciation, tax credit for deemed income and income computation apply as modified by notification, subject to compliance with the RBI scheme and notified conditions; non-compliance removes benefits and permits reassessment and application of procedural provisions.
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.
Branch conversion tax neutrality: capital gains relief and entitlement to carry forward losses subject to notified conditions.
Conversion of an Indian branch of a foreign banking company into an Indian subsidiary yields tax neutrality: capital gains on conversion are exempt and provisions on carry forward/set off of losses, unabsorbed depreciation, tax credit for deemed income and income computation apply as modified by notification, subject to compliance with the RBI scheme and notified conditions; non-compliance removes benefits and permits reassessment and application of procedural provisions.
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