Deduction restrictions for transfer of undertaking: deduction follows successor company; transferor barred from deduction in transfer year. Amendment clarifies that deductions under sub-section (1) follow the undertaking on transfer: in amalgamation the amalgamated company receives the treatment as if amalgamation had not occurred; in demerger the resulting company receives the treatment as if demerger had not occurred; and on succession from a firm or proprietary concern to a company meeting section 47 conditions the successor company is treated likewise. No deduction is allowed to the amalgamating, demerged or predecessor entity in the year of transfer or succession, and the expenditure cannot be claimed under any other provision of the Act.
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Deduction restrictions for transfer of undertaking: deduction follows successor company; transferor barred from deduction in transfer year.
Amendment clarifies that deductions under sub-section (1) follow the undertaking on transfer: in amalgamation the amalgamated company receives the treatment as if amalgamation had not occurred; in demerger the resulting company receives the treatment as if demerger had not occurred; and on succession from a firm or proprietary concern to a company meeting section 47 conditions the successor company is treated likewise. No deduction is allowed to the amalgamating, demerged or predecessor entity in the year of transfer or succession, and the expenditure cannot be claimed under any other provision of the Act.
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