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of <h1>Clause 205 tightens concessional tax treatment: limits deductions, bars legacy hotel credits, caps used machinery value, expands recharacterisation powers</h1> Clause 205 narrows concessional tax treatment by requiring 'total income' to be computed without specified deductions/exemptions, imposing eligibility limits (no split-up/reconstruction except narrow revival carve-out, 20% cap on used machinery value with foreign-used exception, ban on buildings previously qualifying under legacy hotel/convention deductions, and restrictiveness to defined manufacture/production with enumerated exclusions), and empowering the tax authority to recharacterise excess profits from related-party arrangements using arm's-length principles for specified domestic transactions. Key changes from the Bill: the Act removes a two-year sunset on guideline-making (extending administrative discretion) and expands the assessing officer's power to apply deemed-profit adjustments to both sections 201 and 204.
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