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of <h1>Tax-Free Bank Branch Conversion Allows Seamless Restructuring with Preserved Tax Benefits and Regulatory Compliance Mechanisms</h1> Legal Analysis Summary:The text discusses Clause 219 of the Income Tax Bill, 2025, addressing the conversion of a foreign bank's Indian branch into a subsidiary Indian company. The provision offers tax neutrality by exempting capital gains during conversion and preserving tax attributes like losses and depreciation. The clause mandates compliance with regulatory requirements, with strict consequences for non-adherence, including potential retrospective withdrawal of tax benefits. It essentially continues the framework of the existing Section 115JG, providing a structured approach to facilitate regulatory-driven banking sector restructuring while protecting revenue interests through comprehensive anti-abuse mechanisms.
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