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Carry forward of MAT credit for how many years if there is contradiction between statutory provisions and circular issued

There is no ambiguity in the language of sub-section (3) of section 115JAA; the carry forward is available for a total of six (1+5) years; the period of `five assessment years', mentioned in sub-paragraph (2) of the paragraph 45.4 of the CBDT Circular No. 763 dated 18-2-1998, contradicts with what is stated in sub-section (3) of section 115JAA; it is trite law that statutory provisions prevail over a Circular in case of a contradiction between the two.
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