(“TDS”) at applicable rate specified under the Act read with applicable Double Taxation Avoidance
Agreement (if any).

With respect to a resident corporate shareholder, a new section 80M has been inserted in the Act to
remove the cascading effect of taxes on inter-corporate dividends during FY 2020-21 and thereafter. The
section provides that where the gross total income of a domestic company in any previous year includes
any income by way of dividends from any other domestic company or a foreign company or a business
trust, there shall, in accordance with and subject to the provisions of this section, be allowed in computing
the total income of such domestic company, a deduction of an amount equal to so much of the amount
of income by way of dividends received from such other domestic company or foreign company or
business trust as does not exceed the amount of dividend distributed by it on or before the due date. The
“due date” means the date one month prior to the date for furnishing the return of income under sub-
section (1) of section 139 of the Act.

Il. Special direct tax benefits available to Shareholders

There are no special tax benefits available to the shareholders under the provisions of the Income-tax
Act, 1961.

Notes:

1. The benefits in I and II above are as per the current tax law as amended by the Finance Act, 2021.

2. This statement does not discuss any tax consequences in the country outside India of an investment in the
shares. The shareholders / investors in the country outside India are advised to consult their own professional
advisors regarding possible Income tax consequences that apply to them.

3. Surcharge is to be levied on domestic companies at the rate of 7% where the income exceeds INR one crore
but does not exceed INR ten crores and at the rate of 12% where the income exceeds INR ten crores.

4. We understand that the Company has opted for concessional income tax rate under section 115BAA of the
Act. Accordingly, surcharge shall be levied at the rate of 10% irrespective of the amount of total income.

5. Health and Education Cess @ 4% on the tax and surcharge is payable by all category of tax payers.

6. We understand that the Company has opted for concessional tax rate under section 115BAA of the Act. Hence,
it will not be allowed to claim any of the following deductions:

¢ Deduction under the provisions of section 10AA (deduction for units in Special Economic Zone)

¢ Deduction under clause (iia) of sub-section (1) of section 32 (Additional depreciation)

e Deduction under section 32AD or section 33AB or section 33ABA (Investment allowance in
backward areas, Investment deposit account, site restoration fund)

e Deduction under sub-clause (ii) or sub-clause (iia) or sub-clause (iii) of sub-section (1) or sub-section
(2AA) or sub-section (2AB) of section 35 (Expenditure on scientific research)

¢ Deduction under section 35AD or section 35CCC (Deduction for specified business, agricultural
extension project)

¢ Deduction under section 35CCD (Expenditure on skill development)

¢ Deduction under any provisions of Chapter VI-A other than the provisions of section 80JJAA and
section 80M;

© No set off of any loss carried forward or depreciation from any earlier assessment year, if such loss
or depreciation is attributable to any of the deductions referred above;

¢ No set off of any loss or allowance for unabsorbed depreciation deemed so under section 72A, if
such loss or depreciation is attributable to any of the deductions referred above

7. Further, it is also clarified in section 115JB(5A) that if the Company opts for concessional income tax

rate under section 115BAA, the provisions of section 115JB regarding Minimum Alternate Tax (MAT)
are not applicable. Further, such Company will not be entitled to claim tax credit relating to MAT.

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