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of <h1>Tax deduction apportionment for co-operative bank reorganisations: sections 33, 44 and 52(1) prorated by days</h1> Where a co-operative bank undergoes business reorganisation during a tax year, deductions under sections 33, 44 or 52(1) (Table Sl. No. 1 or 2) are apportioned between predecessor and successor (or converted banking company) pro rata by days: the predecessor's allowable deduction equals A × B / C and the successor's equals A × D / C, where A is the deduction had reorganisation not occurred, B is days before reorganisation, D is days from reorganisation to year-end, and C is total days in the year. If an undertaking entitled to deduction transfers to the successor before expiry of the specified period, sections 44 and 52(1) continue to apply to the successor in later years as if no reorganisation occurred.
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