Analysis of S. 115JAA

Carry forward and set off of MAT credit u/s.115JAA and Allowability in the hands of amalgamated company

The reasons in support of and also against the issue under consideration have been set out above. The reasons in support of the argument that, amalgamated company can claim MAT credit of amalgamating company after merger, appears to be reasonable. Such conclusion would also be in accord with the purposive interpretation of the relevant provision. However, the tax authorities may be reluctant to allow MAT credit of the amalgamating company to amalgamated company. This may..
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