Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Deduction u/s 80IA - amalgamating / demerged entity to claim any deduction in the year of amalgamation/ demerger - the clarification provided in the circular for insertion of sub-section (12A) cannot be extended beyond what is unambiguously stated in the provisions of the IT Act. Sub-section (12A) simply states that from a particular date i.e. 31 March 2007 the provisions of sub-section (12) shall not apply in the specified situations. There cannot be any other meaning to such simple provision of the IT Act - sub-section (12A) of section 80IA of the IT Act, merely neutralises applicability of subsection (12) and does not disentitle the successor entities to claim deduction in accordance with section 80IA of the IT Act. - AT
Deduction u/s 80IA - amalgamating / demerged entity to claim any deduction in the year of amalgamation/ demerger - the clarification provided in the circular for insertion of sub-section (12A) cannot be extended beyond what is unambiguously stated in the provisions of the IT Act. Sub-section (12A) simply states that from a particular date i.e. 31 March 2007 the provisions of sub-section (12) shall not apply in the specified situations. There cannot be any other meaning to such simple provision of the IT Act - sub-section (12A) of section 80IA of the IT Act, merely neutralises applicability of subsection (12) and does not disentitle the successor entities to claim deduction in accordance with section 80IA of the IT Act. - AT
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