Section 206 — Special provision for minimum alternate tax and alternate minimum tax

(1)( a) Irrespective of anything contained in any other provision of this
Act, where in the case of an assessee being a company, the income-tax pay-
able on the total income as computed under this Act for a tax year is less than the
minimum alternate tax payable for such tax year, then—
( i) the book profit shall be deemed to be the total income of that assessee
for such tax year; and
( ii) the assessee shall be liable to pay income-tax equal to the minimum
alternate tax.
(b) For the purposes of clause (a), the expressions “minimum alternate tax” means
the amount of tax computed on the book profit—
( i) in case of a company being a unit located in an International Financial
Services Centre and deriving its income solely in convertible foreign
exchange, at the rate of 9%;
( ii) in case of any other company, at a rate of 28[14%].
(c) For the purposes of this section, “book profit” means the profit as shown in the
statement of profit and loss for the relevant tax year prepared as per clause ( f), as
increased by—
( i) income-tax paid or payable and the provision therefor, if any such amount
is debited to the statement of profit and loss, where income-tax shall
include—
( A) any interest charged under this Act;
( B) surcharge, if any, as levied under the Central Acts;
28. Substituted for “15%” by the Finance Act, 2026, w.e.f. 1-4-2026.
( C) Education Cess on income-tax, if any, as levied under the Central
Acts; and
( D) Secondary and Higher Education Cess on income-tax, if any, as
levied under the Central Acts;
( ii) the amounts carried to any reserves, called by any name, if any such
amount is debited to the statement of profit and loss;
( iii) the amount or amounts set aside to provisions made for meeting liabil-
ities, other than ascertained liabilities, if any such amount is debited to
the statement of profit and loss;
( iv) the amount by way of provision for losses of subsidiary companies, if
any such amount is debited to the statement of profit and loss;
( v) dividends paid or proposed, if any such amount is debited to the state -
ment of profit and loss;
( vi) expenditure relatable to any income to which provisions of section 11
apply or any expenditure out of regular income of a registered non-profit
organisation referred in section 335, if any such amount is debited to the
statement of profit and loss;
( vii) depreciation, if any such amount is debited to the statement of profit
and loss;
( viii) deferred tax and the provision therefor, if any such amount is debited to
the statement of profit and loss;
( ix) the amount or amounts set aside as provision for diminution in the value
of any asset, if any such amount is debited to the statement of profit and
loss;
( x) the amount standing in revaluation reserve relating to revalued asset
on the retirement or disposal of such asset, if any such amount is not
credited to the statement of profit and loss,
and as reduced by—
( xi) the amount withdrawn from any reserve or provision (excluding a reserve
created before the 1st April, 1997 otherwise than by way of a debit to the
statement of profit and loss), where,—
( A) any such amount is credited to the statement of profit and loss; and
( B) the book profit of such year has been increased by those reserves
or provisions out of which the said amount was withdrawn;
( xii) income to which any of the provisions of section 11 apply or any
regular income of a registered non-profit organisation referred in
section 33559, if any such amount is credited to the statement of profit
and loss;
( xiii) depreciation debited to the statement of profit and loss excluding the
depreciation on account of revaluation of assets;
( xiv) the amount withdrawn from revaluation reserve and credited to the
statement of profit and loss, to the extent it does not exceed depreciation
on account of revaluation of assets referred to in sub-clause (xiii);
( xv) deferred tax, if any such amount is credited to the statement of profit
and loss;
( xvi) loss brought forward (excluding depreciation) or unabsorbed deprecia-
tion, whichever is less, as per books of account, except, where either
of such amount is nil, in case of a company other than the company
referred to in clause (d)(vi) and (vii),
and as further adjusted by the amounts referred to in clause (d).
(d) While computing the book profit under this section, the following amounts shall
be further adjusted:—
( i) in case of a company being a member of association of persons or body
of individuals having income being share of the assessee in the income of
an association of persons or body of individuals, on which no income-tax
is payable as per the provisions of section 310, then—
( A) the amount or amounts of expenditure relatable to such income if
debited to the statement of profit and loss, is to be added; and
( B) the amount being income if credited to the statement of profit and
loss, is to be reduced;
( ii) in case of a foreign company having income accruing or arising from—
( A) capital gains arising on transactions in securities; or
( B) the interest, dividend, royalty or fees for technical services charge-
able to tax at the rate or rates specified in Chapter XIII,
and the income-tax payable thereon as per the provisions of this Act, other
than the provisions of this Part, is at a rate less than the rate specified
in clause (b), then—
( I) the amount or amounts of expenditure relatable to such income if
debited to the statement of profit and loss, is to be added; and
( II) the amount being income if credited to the statement of profit and
loss, is to be reduced;
( iii) in case of a company, which has transferred any capital asset, being share
of a special purpose vehicle to a business trust,—
( I) the following amounts, if debited to the statement of profit and
loss, are to be added:—
( A) the amount representing the notional loss on transfer of such
capital asset, to a business trust in exchange of units allotted
by the trust referred to in section 70(1)(zi); or
( B) the amount representing the notional loss resulting from any
change in carrying amount of the said units; or
( C) the loss on transfer of units referred to in section 70(1)(zi);
( II) the following amounts, if credited to the statement of profit and
loss, are to be reduced:—
( A) the amount representing the notional gain on transfer of such
capital asset, to a business trust in exchange of units allotted
by the trust referred to in section 70(1)(zi); or
( B) the amount representing the notional gain resulting from any
change in carrying amount of the said units; or
( C) the gain on transfer of units referred to in section 70(1)(zi);
( iv) in case of a company that has transferred units referred to in section
70(1)(zi) and, where the gain or loss on such transfer has been computed
by taking into account—
( A) the cost of the shares exchanged with units referred to in section
70(1)(zi); or
( B) the carrying amount of the shares at the time of exchange, if such
shares are carried at a value other than the cost through statement
of profit and loss,
then, the gain on transfer of such units is to be added, and the loss on
transfer of such units is to be reduced;
( v) in case of a company whose total income includes income by way of
royalty in respect of a patent which is chargeable to tax under section
194(1)—
( A) the amount or amounts of expenditure relatable to such royalty
income, if any such amount is debited to the statement of profit
and loss, is to be added; and
( B) the income by way of such royalty, is to be reduced;
( vi) in case of a company, where the Tribunal, on an application moved by
the Central Government under section 241 of the Companies Act, 2013
(18 of 2013) has after suspension of the Board of Directors of such com-
pany has nominated new directors under section 242 of the said Act,
the aggregate amount of unabsorbed depreciation and loss (excluding
depreciation) brought forward of such company and its subsidiary and
the subsidiary of such subsidiary, is to be reduced;
( vii) in case of a company against whom corporate insolvency resolution
process has been admitted by the Adjudicating Authority under section
7 or 9 or 10 of the Insolvency and Bankruptcy Code, 2016 (31 of 2016),
the aggregate amount of unabsorbed depreciation and loss (excluding
depreciation) brought forward, is to be reduced;
( viii) in case of a company being a sick industrial company under section
17(1) of the Sick Industrial Companies (Special Provisions) Act, 1985
(1 of 1986), as it stood immediately before its repeal by the Sick Industrial
Companies (Special Provisions) Repeal Act, 2003 (1 of 2004), the profits
for the period commencing from the tax year in which such company has
become a sick industrial company and ending with the tax year during
which the entire net worth of such company becomes equal to or exceeds
the accumulated losses, is to be reduced;
( ix) in case of a company, whose financial statements are drawn up in compli-
ance with the Indian Accounting Standards specified in Annexure to the
Companies (Indian Accounting Standards) Rules, 2015 made under the
Companies Act, 2013 (18 of 2013), the amounts mentioned in column A
of the Table below shall be added and the amounts mentioned in column
B of the said Table below are to be reduced:
TABLE
Amounts (to be added) Amounts (to be reduced)
(A) (B)
(1) Amounts credited to the statement
of profit and loss as referred in clause
(e)(i).
(1) Amounts debited to the statement
of profit and loss as referred in clause
(e)(i).
(2) The amounts or aggregate of the
amounts debited to the statement of
profit and loss on distribution as referred
in clause (e)(ii).
(2) The amounts or aggregate of the
amounts credited to the statement of
profit and loss on distribution as referred
in clause (e)(ii).
(3) Amount being one-fifth of the
transition amount in the year of
convergence and each of the following
four tax years.
(3) Amount being one-fifth of the
transition amount in the year of
convergence and each of the following
four tax years.
(4) The amount or the aggregate of the
amounts referred to in clause (e)(iii), if
such amount is not decreased.
(4) The amount or the aggregate of the
amounts referred to in clause (e)(iii), if
such amount is not increased.
(5) The amount or the aggregate of the
amounts referred to in clause ( e)(iv), if
such amount is not decreased.
(5) The amount or the aggregate of the
amounts referred to in clause ( e)(iv), if
such amount is not increased.
(e) For the purposes of the Table in clause (d)(ix),—
( i) the amount referred to in columns A and B of serial number 1 of the said
Table shall be the other comprehensive income in the statement of profit
and loss under the head “Items that will not be re-classified to profit or
loss”, excluding—
( A) revaluation surplus for assets as per the Indian Accounting Stand-
ards 16 and Indian Accounting Standards 38; or
( B) gains or losses from investments in equity instruments designated
at fair value through other comprehensive income as per the Indian
Accounting Standards 109,
and the amount or the aggregate of the amounts referred to in sub-clause
(i)(A) and ( B) for the tax year or any of the preceding tax years, and
relatable to such investment or asset, in the tax year in which the said
investment or asset is retired, disposed, realised or otherwise transferred;
( ii) the distribution referred to in columns A and B of serial number 2 of the
said Table shall be the distribution of non-cash assets to shareholders in
a demerger as per Appendix A of the Indian Accounting Standards 10;
( iii) the amount referred to in columns A and B of serial number 4 of the said
Table shall be the amount which is relatable to the asset or investment
referred to in clause (t)(vi)(B) to (E) for the tax year in which such asset
or investment is retired, disposed, realised or otherwise transferred;
( iv) the amount referred to in columns A and B of serial number 5 of the
said Table shall be the transition amount which is relatable to the foreign
operations referred to in clause (t)(vi)(F) for the tax year in which such
foreign operation is disposed or otherwise transferred.
(f) For the purposes of book profit under clause ( c), every company shall prepare
its statement of profit and loss for the relevant tax year in the following manner:—
( i) in case of an insurance or banking company, or a company engaged in
the generation or supply of electricity, or any other class of company
for which a form of financial statement has been specified under the
enactment governing such class of company, as per the provisions of
such enactment;
( ii) in all other cases, as per the provisions of Schedule III to the Companies
Act, 2013 (18 of 2013).
(g) While preparing the annual accounts including statement of profit and loss by
the company, the—
( i) accounting policies;
( ii) accounting standards adopted for preparing such accounts including
statement of profit and loss; and
( iii) method and rates adopted for calculating the depreciation,
shall be the same as have been adopted for the purpose of preparing such accounts
including statement of profit and loss and laid before the company at its annual
general meeting as per the provisions of section 129 of the Companies Act, 2013
(18 of 2013), or correspond to the accounting policies, accounting standards and
the method and rates for calculating the depreciation which have been adopted for
preparing such accounts including statement of profit and loss for, such financial
year or part of such financial year falling within the relevant tax year, where the
company has adopted or adopts the financial year which is different from the tax
year under this Act.
(h) In the case of a resulting company, where the property and the liabilities of the
undertaking or undertakings being received by it are recorded at values different from
the values appearing in the books of account of the demerged company immediately
before the demerger, any change in such value shall be ignored for the purpose of
computation of book profit of the resulting company under this sub-section.
(i) In the case of an assessee being a company, where—
( i) there is an increase in book profit of the tax year due to income of past
year or years included in the book profit on account of—
( A) an advance pricing agreement entered into by the assessee under
section 168;or
( B) a secondary adjustment required to be made under section 170 68;
and
29[(ii) the assessee has not utilised the credit of tax paid under section 115JAA of
the Income-tax Act, 1961 (43 of 1961), in any subsequent tax year ending
on or before the 31st March, 2026,]
the Assessing Officer shall, on an application made to him in this behalf by the
assessee,—
( I) recompute the book profit of the past year or years and tax payable
under this sub-section, if any, by the assessee during the tax year in such
manner, as may be prescribed; and
( II) the provisions of section 287 shall, so far as may be, apply and the period
of four years specified in sub-sections (7) and (8) of that section shall be
reckoned from the end of the tax year in which the said application is
received by the Assessing Officer.
(j) Irrespective of anything contained in any other provisions of this Act, no interest
shall be payable to an assessee on the refund arising on account of clause (i).
(k) Nothing contained in clause (a) shall affect the determination of the amounts,
in relation to the relevant tax year, to be carried forward to the subsequent year or
years under the provisions of section 33(11) or 111 or 112(1) or 113 or 115.
(l) The provisions of this sub-section shall not be applicable to any assessee, being
a foreign company, where—
( i) the assessee is a resident of a country or a specified territory with which
India has an agreement referred to in section 159(1) or the Central
Government has adopted any agreement under section 159(2) and the
assessee does not have a permanent establishment in India as per the
provisions of such agreement; or
( ii) the assessee is a resident of a country with which India does not have
an agreement of the nature referred to in sub-clause (i) and the assessee
is not required to seek registration under any law for the time being in
force relating to companies; or
( iii) the total income of the assessee comprises solely of profits and gains
from business referred to in section 61(2) 30[***], and such income has
been offered to tax at the rates specified in the respective sections.
29. Substituted by the Finance Act, 2026, w.e.f. 1-4-2026. Prior to its substitution, sub-clause
(ii) read as under :
“( ii) the assessee has not utilised the credit of tax paid under this sub-section in any
subsequent tax year under clauses (m), (n), (o) and (p),”
30. Words “(Table: Sl. Nos. 1, 3, 4 and 5)” omitted by the Finance Act, 2026, w.e.f. 1-4-2026.
(m) 31[***]
(n) 31[***]
(o) 31[***]
(p) 31[***]
(q) The provisions of this 32[sub-section] shall not apply to a person,—
( i) being a company having income accruing or arising from life insurance
business referred to in section 194(1) (Table: Sl. No. 6); or
( ii) who has exercised the option under section 200(5) or section 201(2).
(r) 33[***]
(s) Every company to 34[which this sub-section] applies, shall furnish a report in the
prescribed form from an accountant, certifying that the book profit in its case has
been computed as per the provisions of this section—
( i) before the specified date referred to in section 63; or
( ii) along with the return of income furnished in response to a notice under
section 268(1).
31. Clauses (m), (n), (o) and (p) omitted by the Finance Act, 2026, w.e.f. 1-4-2026. Prior to their
omission, clauses (m), (n), (o) and (p) read as under :
“( m) Where any tax is paid under clause (a) by an assessee, then, credit shall be allowed to
him of an amount in excess of such minimum alternate tax over the tax payable by such
assessee on his total income computed as per the other provisions of this Act for that tax
year.
( n) While allowing credit under clause (m),—
( i) no interest shall be payable on the tax credit so allowed; and
( ii) where tax credit in respect of any income-tax paid in any country or specified territory
outside India, under section 159(1) or (2), allowed against the minimum alternate
tax exceeds such tax credit admissible against the tax payable by the assessee on
its income as per the other provisions of this Act, then, while computing the credit
under clause (m), such excess amount shall be ignored.
( o) (i) The tax credit determined under clause (m) shall be carried forward, and—
( A) set off in a year, when tax payable on the total income computed as per the
provisions of this Act exceeds the minimum alternate tax; and
( B) such set off in respect of brought forward tax credit shall be allowed for any
tax year to the extent of the difference between the tax on his total income and
the minimum alternate tax for that tax year;
( ii) such carry forward of tax credit shall not be allowed beyond the fifteenth tax year
immediately succeeding the tax year in which the tax credit becomes allowable under
clause (m);
( p) Where as a result of any order passed under this Act, tax payable under this Act is
decreased or increased, as the case may be, tax credit allowed under clause (m) shall also be
decreased or increased accordingly.”
32. Substituted for “section” by the Finance Act, 2026, w.e.f. 1-4-2026.
33. Omitted by the Finance Act, 2026, w.e.f. 1-4-2026. Prior to its omission, clause ( r) read as
under :
“( r) In case of conversion of a private company or unlisted public company into a limited
liability partnership under the Limited Liability Partnership Act, 2008 (6 of 2009), the pro-
visions of clauses (m) to (p) shall not apply to the successor limited liability partnership.”
34. Substituted for “which this section” by the Finance Act, 2026, w.e.f. 1-4-2026.
(t) For the purposes of this sub-section,—
( i) “Adjudicating Authority” shall have the same meaning as assigned to it in
section 5(1) of the Insolvency and Bankruptcy Code, 2016 (31 of 2016);
( ii) “convergence date” means the first day of the first Indian Account -
ing Standards reporting period as defined in the Indian Accounting
Standards 101;
( iii) “net worth” shall have the meaning assigned to it in section 3(1)(ga) of the
Sick Industrial Companies (Special Provisions) Act, 1985 (1 of 1986), as
it stood immediately before its repeal by the Sick Industrial Companies
(Special Provisions) Repeal Act, 2003 (1 of 2004);
( iv) “private company” and “unlisted public company” shall have the mean-
ings respectively assigned to them in the Limited Liability Partnership
Act, 2008 (6 of 2009);
( v) “securities” shall have the same meaning as assigned to it in section 2(h)
of the Securities Contracts (Regulation) Act, 1956 (42 of 1956)87;
( vi) “transition amount” means the amount or the aggregate of the amounts
adjusted in the other equity (excluding capital reserve and securities
premium reserve) on the convergence date, but not including the
following:—
(A) amount or aggregate of the amounts adjusted in the other compre-
hensive income on the convergence date which shall be subsequently
re-classified to the profit or loss;
( B) revaluation surplus for assets as per the Indian Accounting Standards
16 and Indian Accounting Standards 38 adjusted on the convergence
date;
( C) gains or losses from investments in equity instruments designated
at fair value through other comprehensive income as per the Indian
Accounting Standards 109 adjusted on the convergence date;
( D) adjustments relating to items of property, plant and equipment
and intangible assets recorded at fair value as deemed cost as per
paragraphs D5 and D7 of the Indian Accounting Standards 101 on
the convergence date;
( E) adjustments relating to investments in subsidiaries, joint ven -
tures and associates recorded at fair value as deemed cost as per
paragraph D15 of the Indian Accounting Standards 101 on the
convergence date; and
( F) adjustments relating to cumulative translation differences of a
foreign operation as per paragraph D13 of the Indian Accounting
Standards 101 on the convergence date;
( vii) “Tribunal” shall have the same meaning as assigned to it in section 2(90)
of the Companies Act, 2013 (18 of 2013);
( viii) “Unit” means a unit established in an International Financial Services
Centre;
( ix) “year of convergence” means the tax year within which the convergence
date falls; and
( x) a company shall be a subsidiary of another company, if such other
company holds more than half in the nominal value of equity share
capital of the company.
(2) (a) Irrespective of anything contained in this Act, where the regular income-tax
payable for a tax year by a person, other than a company, is less than the alternate
minimum tax payable for such tax year, then,—
( i) the adjusted total income shall be deemed to be the total income of that
person for such tax year; and
( ii) he shall be liable to pay income-tax equal to the alternate minimum tax.
(b) For the purposes of this sub-section,—
( i) “adjusted total income” shall be the total income before giving effect to
clause (a), as increased by deductions claimed, if any, under—
( I) any section (other than section 149) included in Chapter VIII-C;
( II) section 46 as reduced by depreciation allowable as per the provi -
sions of section 33, as if no deduction was allowed in respect of the
assets on which the deduction under that section is claimed;
( ii) “alternate minimum tax” means the amount of tax computed on adjusted
total income,—
( I) in case of an assessee being a unit located in an International
Financial Services Centre and deriving its income solely in convert-
ible foreign exchange, at the rate of 9%;
( II) in case of an assessee being a co-operative society, at the rate of
15%;
( III) in any other case, at a rate of 18.5%;
( iii) “regular income-tax” means the income-tax payable for a tax year by a
person on his total income in accordance with the provisions of this Act
other than the provisions of this sub-section;
( iv) “Unit” means a unit established in an International Financial Services
Centre.
(c) The provisions of this sub-section shall apply to a person who has claimed any
deduction under any section (other than section 14992) included in Chapter VIII-C
or section 46.
(d) The provisions of this sub-section shall not apply to—
( i) a person, who has exercised the option under section 203(5) or section
204(2);
( ii) a person, whose income-tax payable in respect of the total income of
such person is computed under section 202(1);
( iii) an individual or a Hindu undivided family or an association of persons
or a body of individuals, whether incorporated or not, or an artificial
juridical person referred to in section 2(77)(g), if the adjusted total income
of such person does not exceed twenty lakh rupees; or
( iv) any specified fund referred to in Schedule VI (Note 1).
(e) Where any tax is paid under clause (a) by an assessee, then, credit shall be allowed
to him of an amount which shall be the excess of alternate minimum tax over the
regular income-tax payable of that year.
(f) While allowing credit under clause (e),—
( i) no interest shall be payable on the tax credit so allowed; and
( ii) where tax credit in respect of any income-tax paid in any country or
specified territory outside India, under section 159(1) or (2), allowed
against the alternate minimum tax payable exceeds such tax credit
admissible against the regular income-tax payable by the assessee, then,
while computing the credit under clause ( e), such excess amount shall
be ignored.
(g) Tax credit determined under clause (e) shall be carried forward and—
( i) set off in a year, when the regular income-tax exceeds the alternate
minimum tax; and
( ii) such set off in respect of brought forward tax credit shall be allowed for
any tax year to the extent of the excess of regular income-tax over the
alternate minimum tax for that tax year,
and such carry forward shall not be allowed beyond the fifteenth tax year immediately
succeeding the tax year in which the tax credit becomes allowable under clause (e).
(h) Where as a result of any order passed under this Act, tax payable under this Act
is reduced or increased, tax credit allowed under clause ( e) shall also be reduced
or increased accordingly.
(i) Irrespective of anything contained in clause ( c) or clause (d), the credit for tax
paid under clause (a) shall be allowed in accordance with the provisions of clauses
(e), (f), (g) and (h).
(j) Every person to which this sub-section applies, shall furnish a report in the
prescribed form from an accountant, certifying that the adjusted total income and
alternate minimum tax in its case have been computed as per the provisions of this
sub-section before the specified date referred to in section 63.
35[(3)(a) The provisions of this sub-section shall be applicable only to an assessee, being
a domestic company, that has exercised the option under section 200(5) or section
201(2) for a tax year, beginning on or after the 1st April, 2026.
(b) Where any amount of credit, in respect of tax paid, was allowed to be carried forward
to the assessee under the provisions of section 115JAA of the Income-tax Act, 1961
(43 of 1961), as on 31st March, 2026,––
35. Sub-sections (3), (4) and (5) substituted for sub-section (3) by the Finance Act, 2026, w.e.f.
1-4-2026. Prior to its substitution, sub-section (3) read as under :
“(3) Save as otherwise provided in this section, all other provisions of this Act shall apply to
every assessee mentioned in this section.”
( i) such credit brought forward shall be allowed to be set off in any tax year to
the extent of 25% of the tax payable on the total income computed as per
the other provisions of this Act for that tax year;
( ii) the remaining credit shall be carried forward to the subsequent tax year;
and
( iii) such carry forward or set off of tax credit shall not be allowed beyond the
fifteenth tax year immediately succeeding the tax year in which the tax
credit first became allowable under section 115JAA of the Income-tax Act,
1961 (43 of 1961).
(c) Where, as a result of any order passed under this Act, tax payable under this Act is
decreased or increased, as the case may be, tax credit allowed to be set off under clause
(b) shall also be decreased or increased, accordingly.
(d) In case of conversion of a private company or unlisted public company into a
limited liability partnership under the Limited Liability Partnership Act, 2008 (6 of
2009), the provisions of clauses ( a) and (b) shall not apply to the successor limited
liability partnership.
(4)(a) The provisions of this sub-section shall be applicable only to an assessee, being
a foreign company.
(b) Where, any amount of credit in respect of tax paid was allowed to be carried forward
to the assessee under the provisions of section 115JAA of the Income-tax Act, 1961
(43 of 1961), as on 31st March, 2026,––
( i) such tax credit shall be carried forward and set off in a tax year, when tax
payable on the total income computed as per the provisions of this Act
exceeds the minimum alternate tax computed as per provisions of sub-
section (1);
( ii) such set off in respect of brought forward tax credit shall be allowed for any
tax year to the extent of the difference between the tax liability on the total
income computed as per the other provisions of this Act and the minimum
alternate tax for that tax year; and
( iii) such carry forward or set off of tax credit shall not be allowed beyond the
fifteenth tax year immediately succeeding the tax year in which the tax
credit first became allowable under section 115JAA of the Income-tax Act,
1961 (43 of 1961).
(c) Where, as a result of any order passed under this Act, tax payable under this Act is
decreased or increased, as the case may be, tax credit allowed to be set off under clause
(b) shall also be decreased or increased, accordingly.
(d) In case of conversion of a private company or unlisted public company into a
limited liability partnership under the Limited Liability Partnership Act, 2008 (6 of
2009), the provisions of clauses ( a) and (b) shall not apply to the successor limited
liability partnership.
(5) Save as otherwise provided in this section, all other provisions of this Act shall
apply to every assessee mentioned in this section.]
E.—Special provisions relating to non-residents and foreign companies