Company status for assessment may be treated for foreign corporations and requires board declaration for certain institutions, altering liabilities. Foreign bodies corporate are treated as companies for assessment years from the amendment's effective date without Board declaration; declarations are required for foreign bodies seeking earlier treatment and for any institution seeking company status for any assessment year. ITOs must examine such requests per established criteria, report through CsIT with earliest taxable year, income sources, prior assessments and tax variation, and forward constitutional documents. The Board may make retrospective declarations only back to the prescribed earliest assessment year and not earlier.
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.
Company status for assessment may be treated for foreign corporations and requires board declaration for certain institutions, altering liabilities.
Foreign bodies corporate are treated as companies for assessment years from the amendment's effective date without Board declaration; declarations are required for foreign bodies seeking earlier treatment and for any institution seeking company status for any assessment year. ITOs must examine such requests per established criteria, report through CsIT with earliest taxable year, income sources, prior assessments and tax variation, and forward constitutional documents. The Board may make retrospective declarations only back to the prescribed earliest assessment year and not earlier.
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