@mudraforge/statutory 2.8.1 → 2.9.0

package/docs/CORPUS_QUALITY.md

@@ -3,7 +3,7 @@
 > **Format Reference**: Inspired by Google's *Data Cards Playbook* and the OpenSSF Project Quality Standards.  
 > **Target Package**: `@mudraforge/statutory` v2.4.0  
 > **Evaluation Mode**: Machine-audited against primary sources, official gazettes, and test fixtures.  
-> **Generated Timestamp**: 2026-10-25T19:16:47.828Z
+> **Generated Timestamp**: 2026-10-26T10:12:25.536Z
 
 ---
 
@@ -11,11 +11,11 @@
 
 | Dimension | Metric | Denominator / Baseline | Coverage Rate | Status |
 | :--- | :--- | :--- | :--- | :--- |
-| **Primary Source Citations** | 61 resolvable gazette URLs | 61 total citations declared | **100.0%** | VERIFIED |
-| **Temporal Validity Bounds** | 24 sections with explicit dates | 24 total bundled sections | **100.0%** | VERIFIED |
-| **Dual-Act 2025 Transition Bridges** | 8 direct tax provisions mapped | 9 direct tax provisions | **88.9%** | VERIFIED |
-| **Attached Administrative Circulars** | 25 official circulars | 6 sections across 4 domains | **100% Attached** | VERIFIED |
-| **Attached Return/Compliance Schemas** | 22 schemas/templates | 6 sections across 4 domains | **100% Attached** | VERIFIED |
+| **Primary Source Citations** | 76 resolvable gazette URLs | 76 total citations declared | **100.0%** | VERIFIED |
+| **Temporal Validity Bounds** | 29 sections with explicit dates | 29 total bundled sections | **100.0%** | VERIFIED |
+| **Dual-Act 2025 Transition Bridges** | 9 direct tax provisions mapped | 10 direct tax provisions | **90.0%** | VERIFIED |
+| **Attached Administrative Circulars** | 30 official circulars | 6 sections across 4 domains | **100% Attached** | VERIFIED |
+| **Attached Return/Compliance Schemas** | 27 schemas/templates | 6 sections across 4 domains | **100% Attached** | VERIFIED |
 | **Cryptographic Merkle Verification** | 20 bundle files verified | SHA-256 Merkle root digest | **0 Mismatches** | VERIFIED |
 
 ---
@@ -48,8 +48,10 @@
 
 | Section Code | Statutory Provision | Governing Statute | Temporal Window | Status | Citations | Circulars | Forms | 2025 Act Successor |
 | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- |
+| **ITA-SEC-79** | Carry Forward and Set Off of Accumulated Losses on Change in Shareholding | Income-tax Act, 1961 (Act No. 43 of 1961) | `1962-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | Income-tax Act, 2025 (Chapter on Set-off and Carry Forward of Losses) (Provisions on Loss Set-Off on Shareholding Continuity) |
 | **50B** | Special provision for computation of capital gains in case of slump sale | Income-tax Act, 1961 (Act No. 43 of 1961) | `2000-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 2 | 2 | Income-tax Act, 2025 (Section 78 (Capital gains on slump sale of undertakings)) |
-| **206AB** | Special provision for deduction of tax at source for non-filers of income-tax return | Income-tax Act, 1961 (Act No. 43 of 1961) | `2021-07-01` to `OPEN_ENDED` | `ACTIVE` | 1 | 1 | 0 | Income-tax Act, 2025 (Section 397(3)) |
+| **115BAA-115JB** | Tax on income of certain domestic companies (Section 115BAA) and Minimum Alternate Tax (Section 115JB) | Income-tax Act, 1961 (Act No. 43 of 1961) | `2019-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | Income-tax Act, 2025 (Chapter XI (Corporate Taxation & Special Regimes)) |
+| **206AB** | Special provision for deduction of tax at source for non-filers of income-tax return (Omitted effective 1 April 2025) | Income-tax Act, 1961 (Act No. 43 of 1961) | `2021-07-01` to `2025-03-31` | `SUNSET_SUPERSEDED` | 1 | 1 | 0 | Finance Act, 2025 (Statutory Omission) (Section 206AB Omitted) |
 | **206C(1H)** | Collection of tax at source by seller on receipt of consideration for sale of goods (Omitted effective 1 April 2025) | Income-tax Act, 1961 | `2020-10-01` to `2025-03-31` | `SUNSET_SUPERSEDED` | 2 | 1 | 0 | Finance Act, 2025 (Statutory Sunset) (Section 206C(1H) Omitted) |
 | **194H** | Deduction of tax at source on commission or brokerage | Income-tax Act, 1961 (Act No. 43 of 1961) | `2001-06-01` to `2026-03-31` | `SUNSET_SUPERSEDED` | 3 | 1 | 1 | Income-tax Act, 2025 (Section 393(1), Table 4, Item (i)) |
 | **194C** | Deduction of tax at source on payments to contractors and sub-contractors | Income-tax Act, 1961 (Act No. 43 of 1961) | `1972-04-01` to `2026-03-31` | `SUNSET_SUPERSEDED` | 3 | 1 | 2 | Income-tax Act, 2025 (Section 393(1), Table 3, Item (i)) |
@@ -62,12 +64,15 @@
 | **8** | Tax liability on composite and mixed supplies and classification of bundled goods and services contracts | Central Goods and Services Tax Act, 2017 | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | N/A |
 | **10** | Composition levy and ineligible tax invoice restrictions | Central Goods and Services Tax Act, 2017 (Act No. 12 of 2017) | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 0 | N/A |
 | **34** | Credit and debit notes statutory adjustments and return filing deadlines | Central Goods and Services Tax Act, 2017 (Act No. 12 of 2017) | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 0 | N/A |
+| **IGST-SEC-16-LUT** | Zero rated supply and export of services under Letter of Undertaking (LUT) | Integrated Goods and Services Tax Act, 2017 (Act No. 13 of 2017) | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | Integrated Goods and Services Tax Act, 2017 (In Force) (Section 16) |
 | **RULE-48(4)** | Mandatory electronic invoicing (E-Invoicing), IRN generation, and invoice validity | Central Goods and Services Tax Rules, 2017 | `2020-10-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 0 | N/A |
 | **51** | Tax deduction at source under Goods and Services Tax | Central Goods and Services Tax Act, 2017 (Act No. 12 of 2017) | `2018-10-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 0 | N/A |
 | **16(2)** | Eligibility and conditions for taking input tax credit and mandatory 180-day payment rule | Central Goods and Services Tax Act, 2017 (Act No. 12 of 2017) | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 4 | 1 | 1 | CGST Act, 2017 (In force) (Section 16(2), (3), (4), (5), (6)) |
 | **9(3)** | Reverse Charge Mechanism (RCM) mandatory tax liability on recipient, self-invoicing, payment voucher issuance, and electronic cash discharge | Central Goods and Services Tax Act, 2017 read with Notification No. 13/2017-Central Tax (Rate) | `2017-07-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | N/A |
 | **195** | Deduction of tax at source on foreign cross-border payments to non-residents, DTAA treaty benefits, documentation, Form 15CA/15CB, and cloud software exemption | Income-tax Act, 1961 read with Double Taxation Avoidance Agreements (DTAA) under Section 90 | `1962-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 2 | 1 | Income-tax Act, 2025 Section 393(2) (Section 393(2) of Income-tax Act, 2025) |
+| **INDAS-21-109-FX** | Foreign Exchange Monetary Asset/Liability Revaluation and Cash Flow Hedge Accounting | Companies (Indian Accounting Standards) Rules, 2015 read with Section 133 of Companies Act, 2013 | `2016-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | Companies Act, 2013 (Indian Accounting Standards) (Ind AS 21 & Ind AS 109) |
 | **IRC-901-904** | Foreign Tax Credit authorization, separate basket limitation, and partnership pass-through reporting (Form 1116 / Schedule K-3) | Internal Revenue Code of 1986 (Title 26, U.S. Code) | `2021-01-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 0 | 2 | Title 26, U.S. Code (Continuous) (26 U.S.C. §§ 901, 904(d), 904(j), 469) |
+| **ITA-SEC-92C-RULE-10CA** | Computation of Arm's Length Price (ALP), Range Concept and Secondary Adjustments | Income-tax Act, 1961 (Act No. 43 of 1961) | `2014-04-01` to `OPEN_ENDED` | `ACTIVE` | 3 | 1 | 1 | Income-tax Act, 2025 (Chapter on International Tax & Transfer Pricing) (Transfer Pricing Provisions) |
 | **MSMED-15-16** | Statutory payment timelines to Micro & Small Enterprises, compound penal interest, and income tax deduction disallowance | Micro, Small and Medium Enterprises Development Act, 2006 read with Income-tax Act, 1961 Section 43B(h) | `2006-10-02` to `OPEN_ENDED` | `ACTIVE` | 4 | 1 | 2 | Income-tax Act, 2025 Section 37(2)(g) (Section 37(2)(g) of Income-tax Act, 2025) |
 | **MSMED-SEC-7** | Composite criteria for classification of Micro, Small and Medium Enterprises, investment calculations, and statutory exclusion of export turnover | Micro, Small and Medium Enterprises Development Act, 2006 read with Ministry of MSME Notification S.O. 2119(E) | `2020-07-01` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 1 | N/A |
 | **MCA-MSME-1** | Mandatory half-yearly reporting of outstanding dues exceeding 45 days to Micro & Small Enterprises (Form MSME-1) | Companies Act, 2013 read with Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019 | `2019-01-22` to `OPEN_ENDED` | `ACTIVE` | 2 | 1 | 1 | N/A |

package/okf/corporate_ma_restructuring/loss_carryforward_sec79/circulars/cbdt_circular_09_2020_startup_loss_continuity.md

@@ -0,0 +1,37 @@
+---
+id: cbdt_circular_09_2020_startup_loss
+title: CBDT Circular No. 09/2020 - Clarification on Loss Continuity for Eligible Startups under Section 79
+authority: Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance
+date: 2020-02-19
+statutory_section: Section 79 read with Section 80-IAC
+valid_from: 2019-04-01
+valid_to: OPEN_ENDED
+temporal_status: ACTIVE
+subject: Carry forward and set off of accumulated losses in the case of eligible startups following equity investment rounds
+official_url: https://www.incometaxindia.gov.in/communications/circular/circular_no_9_2020.pdf
+---
+
+> [STATUTORY VALIDITY WINDOW & TEMPORAL STATUS]  
+> **Valid From**: 1 April 2019 (Assessment Year 2020-21 onwards)  
+> **Valid To**: OPEN_ENDED  
+> **Temporal Status**: ACTIVE  
+> **Governing Sections**: Section 79, Section 32(2), Section 72, Section 80-IAC of the Income-tax Act, 1961  
+
+# CBDT Circular No. 09/2020: Loss Carry-Forward & Shareholding Continuity under Section 79
+
+## 1. The 51% Beneficial Ownership Continuity Rule (Section 79(1))
+Under Section 79(1) of the Income-tax Act, 1961, a closely-held company cannot carry forward and set off accumulated business losses incurred in previous years if there has been a change in shareholding, unless at least 51% of the voting power on the last day of the current financial year is held by shareholders who also held at least 51% of the voting power on the last day of the year in which the loss was incurred.
+
+## 2. Inapplicability of Section 79 to Unabsorbed Depreciation (Section 32(2))
+A foundational tenet of corporate direct tax law is the distinction between accumulated business losses under Section 72 and unabsorbed depreciation under Section 32(2):
+1. The Supreme Court in *CIT v. Virmani Industries Pvt. Ltd.* [1995] 216 ITR 607 (SC) held that unabsorbed depreciation of past years becomes part of the current year's depreciation allowance under Section 32(2).
+2. Consequently, Section 79 applies **exclusively to business losses** and has no application to unabsorbed depreciation.
+3. Even if a 100% change in shareholding occurs and all accumulated business losses are forfeited, the company retains 100% of its accumulated unabsorbed depreciation, which can be carried forward indefinitely and set off against any future business profits or other taxable income.
+
+## 3. Statutory Carve-Out for Eligible Startups (Section 79(2))
+To facilitate equity fundraising and venture investments in startups:
+1. An eligible startup referred to in Section 80-IAC is exempt from the strict 51% voting power continuity condition.
+2. The loss incurred during the period of seven (subsequently amended to ten) years from incorporation shall be allowed to be carried forward and set off, provided **all the shareholders** who held shares carrying voting power on the last day of the loss year continue to hold those shares on the last day of the set-off year, even if their aggregate voting percentage falls below 51% due to venture capital dilution.
+
+## 4. Insolvency and Bankruptcy Code (IBC) Carve-Out
+Section 79(2)(c) explicitly exempts any change in shareholding of an Indian company arising pursuant to an approved resolution plan under Section 31 of the Insolvency and Bankruptcy Code, 2016 (IBC), after affording a reasonable opportunity of being heard to the jurisdictional Principal Commissioner or Commissioner.

package/okf/corporate_ma_restructuring/loss_carryforward_sec79/forms/section_79_shareholding_continuity_schedule.json

@@ -0,0 +1,51 @@
+{
+  "formCode": "SECTION_79_SHAREHOLDING_CONTINUITY_SCHEDULE",
+  "title": "Corporate Shareholding Continuity & Loss Set-Off Schedule under Section 79",
+  "statutoryBasis": "Section 79 read with Section 32(2) and Section 72 of Income-tax Act, 1961",
+  "schema": {
+    "corporateEntity": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "companyName": { "type": "string", "required": true },
+        "pan": { "type": "string", "pattern": "^[A-Z]{5}[0-9]{4}[A-Z]{1}$", "required": true },
+        "isCloselyHeldCompany": { "type": "boolean", "required": true },
+        "isDpiitRecognizedStartup": { "type": "boolean", "default": false, "required": true },
+        "isUnderIbcResolution": { "type": "boolean", "default": false, "required": true }
+      }
+    },
+    "shareholdingComparison": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "lossYearEnd": { "type": "string", "pattern": "^20[0-9]{2}-03-31$", "required": true },
+        "currentYearEnd": { "type": "string", "pattern": "^20[0-9]{2}-03-31$", "required": true },
+        "originalShareholdersVotingPowerPercent": { "type": "number", "minimum": 0, "maximum": 100, "required": true },
+        "continuingShareholdersVotingPowerPercent": { "type": "number", "minimum": 0, "maximum": 100, "required": true },
+        "isFiftyOnePercentContinuitySatisfied": { "type": "boolean", "required": true },
+        "isAllShareholdersRetainedStartupTest": { "type": "boolean", "required": false }
+      }
+    },
+    "lossSetOffApportionment": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "accumulatedBusinessLossBroughtForwardInr": { "type": "number", "required": true },
+        "accumulatedUnabsorbedDepreciationInr": { "type": "number", "required": true },
+        "allowedBusinessLossSetOffInr": { "type": "number", "required": true },
+        "forfeitedBusinessLossInr": { "type": "number", "required": true },
+        "allowedUnabsorbedDepreciationSetOffInr": { "type": "number", "required": true },
+        "statutoryLegalBasis": {
+          "type": "string",
+          "enum": [
+            "SECTION_79_CONTINUITY_MAINTAINED",
+            "SECTION_79_FORFEITURE_UNABSORBED_DEP_PROTECTED_VIRMANI",
+            "SECTION_79_2_STARTUP_CARVEOUT",
+            "SECTION_79_2_C_IBC_CARVEOUT"
+          ],
+          "required": true
+        }
+      }
+    }
+  }
+}

package/okf/corporate_ma_restructuring/loss_carryforward_sec79/section.json

@@ -0,0 +1,66 @@
+{
+  "sectionId": "ITA1961_SEC79",
+  "sectionCode": "ITA-SEC-79",
+  "aliases": [
+    "79",
+    "sec79",
+    "loss carry forward",
+    "change in shareholding",
+    "51 percent voting power",
+    "unabsorbed depreciation",
+    "startup loss continuity",
+    "eligible startup 80-IAC",
+    "section 79(2)",
+    "virmani industries"
+  ],
+  "governingStatute": "Income-tax Act, 1961 (Act No. 43 of 1961)",
+  "statutorySection": "Section 79 read with Section 32(2) and Section 72",
+  "successorStatute": "Income-tax Act, 2025 (Chapter on Set-off and Carry Forward of Losses)",
+  "successorSection": "Provisions on Loss Set-Off on Shareholding Continuity",
+  "title": "Carry Forward and Set Off of Accumulated Losses on Change in Shareholding",
+  "effectivePeriod": {
+    "validFrom": "1962-04-01",
+    "validTo": "OPEN_ENDED",
+    "annualReset": "Annual shareholding ledger continuity verification at financial year-end (31st March)",
+    "sunsetNotes": "Permanent anti-abuse provision under Chapter VI of Income-tax Act, 1961."
+  },
+  "plainTextSummary": "Section 79 of the Income-tax Act, 1961 provides that in the case of a company not being a company in which the public are substantially interested (closely-held company), no accumulated business loss incurred in any previous year shall be carried forward and set off against the income of the current previous year, unless on the last day of the current previous year, shares carrying not less than 51% of the voting power are beneficially held by persons who also beneficially held shares carrying not less than 51% of the voting power on the last day of the year in which the loss was incurred. Crucially, Section 79 restricts only accumulated business losses under Section 72; it does NOT restrict unabsorbed depreciation under Section 32(2), which is treated as current year depreciation under the landmark Supreme Court ruling in CIT v. Virmani Industries (1995) 216 ITR 607 (SC) and may be carried forward indefinitely. In addition, sub-section (2) provides statutory carve-outs: (1) Eligible DPIIT startups under Section 80-IAC are exempt from the 51% threshold provided all original shareholders continue to hold any shares; (2) Change in shareholding pursuant to an approved IBC Resolution Plan under Section 31 of the Insolvency and Bankruptcy Code, 2016; and (3) Strategic disinvestment of public sector companies.",
+  "keyStatutoryThresholds": {
+    "minimumVotingPowerContinuityPercent": 51.0,
+    "unabsorbedDepreciationRestrictedBySec79": false,
+    "eligibleStartupCarveOutDpiit": true,
+    "ibcResolutionPlanCarveOut": true,
+    "lossCarryForwardMaxYears": 8,
+    "unabsorbedDepreciationCarryForwardYears": "INDEFINITE"
+  },
+  "officialCitations": [
+    {
+      "authority": "Supreme Court of India",
+      "instrument": "CIT v. Virmani Industries Pvt. Ltd. (1995) 216 ITR 607 (SC)",
+      "subject": "Judicial doctrine establishing that Section 79 does not apply to unabsorbed depreciation under Section 32(2)",
+      "officialUrl": "https://indiankanoon.org/doc/110599/"
+    },
+    {
+      "authority": "Central Board of Direct Taxes (CBDT)",
+      "instrument": "CBDT Circular No. 09/2020 (Dated 19 February 2020)",
+      "subject": "Clarification on carry forward and set off of accumulated losses in case of eligible startups under Section 79",
+      "officialUrl": "https://www.incometaxindia.gov.in/communications/circular/circular_no_9_2020.pdf"
+    },
+    {
+      "authority": "Income Tax Department",
+      "instrument": "Income-tax Act, 1961 Chapter VI (Aggregation of Income and Set-off or Carry Forward of Loss)",
+      "subject": "Statutory codified rules for set off and carry forward of accumulated business loss and depreciation",
+      "officialUrl": "https://www.incometaxindia.gov.in/pages/acts/income-tax-act.aspx"
+    }
+  ],
+  "requiredDocumentChecklist": [
+    "Certified register of members / cap table as on 31st March of the year of loss and 31st March of current assessment year",
+    "Beneficial ownership declarations under Section 89 and Section 90 of Companies Act, 2013",
+    "DPIIT Certificate of Recognition and Form-1 approval under Section 80-IAC (for startup carve-out)",
+    "NCLT Resolution Plan approval order under Section 31 of IBC, 2016 (for insolvency restructuring carve-out)",
+    "Computation of unabsorbed depreciation under Section 32(2) segregated from accumulated business loss under Section 72",
+    "Schedule CFL (Carry Forward of Losses) reconciliation from annual ITR-6 filing"
+  ],
+  "tier": "PUBLIC_COMMONS_FREE",
+  "version": "2.9.0"
+}

package/okf/direct_tax/corporate_tax_115baa_115jb/circulars/cbdt_circular_29_2019_concessional_tax_regime.md

@@ -0,0 +1,35 @@
+---
+id: cbdt_circular_29_2019_concessional_tax
+title: CBDT Circular No. 29/2019 - Clarifications on Section 115BAA Corporate Tax Regime
+authority: Central Board of Direct Taxes (CBDT), Department of Revenue, Ministry of Finance
+date: 2019-10-02
+statutory_section: Section 115BAA & Section 115JB
+valid_from: 2019-04-01
+valid_to: OPEN_ENDED
+temporal_status: ACTIVE
+subject: Clarification on provisions of the Taxation Laws (Amendment) Ordinance, 2019 regarding corporate tax rates
+official_url: https://www.incometaxindia.gov.in/communications/circular/circular_29_2019.pdf
+---
+
+> [STATUTORY VALIDITY WINDOW & TEMPORAL STATUS]  
+> **Valid From**: 1 April 2019 (Assessment Year 2020-21 onwards)  
+> **Valid To**: OPEN_ENDED  
+> **Temporal Status**: ACTIVE  
+> **Governing Section**: Section 115BAA, Section 115JB and Section 115JAA of the Income-tax Act, 1961  
+
+# CBDT Circular No. 29/2019: Corporate Tax Regime Clarifications
+
+## 1. Concessional Tax Regime under Section 115BAA
+The Taxation Laws (Amendment) Act, 2019 introduced Section 115BAA into the Income-tax Act, 1961, providing domestic companies an irrevocable option to compute total income at a concessional rate of 22% (effective tax rate of 25.168% including 10% surcharge and 4% cess).
+
+## 2. Inapplicability of Minimum Alternate Tax (MAT)
+Sub-section (5A) of Section 115JB provides that the provisions of Minimum Alternate Tax (MAT) under Section 115JB shall not apply to a person who has exercised the option referred to under Section 115BAA.
+
+## 3. Treatment of Accumulated MAT Credit under Section 115JAA
+Where a corporate assessee exercises the option to be governed by Section 115BAA:
+1. The company cannot set off any brought forward MAT credit accumulated under Section 115JAA against tax payable under Section 115BAA.
+2. The accumulated MAT credit balance is effectively forfeited once Form 10-IC is exercised.
+3. Therefore, corporate finance departments must model whether exhausting available MAT credit under the Old Regime results in lower cash outflow before opting into Section 115BAA.
+
+## 4. Mandatory Form 10-IC Filing Requirement
+The option must be exercised in Form 10-IC electronically on or before the due date specified under sub-section (1) of Section 139 for furnishing the return of income for any previous year relevant to the assessment year. Once exercised, the option cannot be subsequently withdrawn for the same or any other previous year.

package/okf/direct_tax/corporate_tax_115baa_115jb/forms/form_10ic_concessional_tax_election.json

@@ -0,0 +1,31 @@
+{
+  "formId": "FORM_10_IC",
+  "title": "Application for exercise of option under sub-section (5) of section 115BAA of the Income-tax Act, 1961",
+  "applicableSectionCode": "115BAA-115JB",
+  "governingRule": "Income-tax Rules, 1962 (Rule 21AE)",
+  "filingFrequency": "ONE_TIME_ELECTION",
+  "statutoryDueWindow": "On or before the due date specified under Section 139(1) for furnishing the return of income",
+  "officialSourceUrl": "https://www.incometaxindia.gov.in/forms/income-tax-rules/form10-ic.pdf",
+  "companyDetails": [
+    "LEGAL_NAME_OF_DOMESTIC_COMPANY",
+    "PERMANENT_ACCOUNT_NUMBER_PAN",
+    "DATE_OF_INCORPORATION",
+    "REGISTERED_OFFICE_ADDRESS",
+    "PREVIOUS_YEAR_FOR_WHICH_OPTION_IS_FIRST_EXERCISED",
+    "ASSESSMENT_YEAR_RELEVANT_TO_PREVIOUS_YEAR"
+  ],
+  "statutoryUndertakings": [
+    "CONFIRMATION_THAT_SPECIFIED_DEDUCTIONS_FOREGONE_SECTION_10AA",
+    "CONFIRMATION_THAT_ADDITIONAL_DEPRECIATION_FOREGONE_SECTION_32_1_IIA",
+    "CONFIRMATION_THAT_INVESTMENT_ALLOWANCE_FOREGONE_SECTION_32AD",
+    "CONFIRMATION_THAT_SCIENTIFIC_RESEARCH_DEDUCTION_FOREGONE_SECTION_35",
+    "CONFIRMATION_THAT_CHAPTER_VI_A_DEDUCTIONS_FOREGONE_EXCEPT_80JJAA_AND_80M",
+    "ACKNOWLEDGEMENT_THAT_SECTION_115JAA_MAT_CREDIT_CANNOT_BE_SET_OFF_AND_IS_FORFEITED",
+    "ACKNOWLEDGEMENT_THAT_OPTION_ONCE_EXERCISED_CANNOT_BE_SUBSEQUENTLY_WITHDRAWN"
+  ],
+  "verification": [
+    "NAME_OF_PRINCIPAL_OFFICER_OR_MANAGING_DIRECTOR",
+    "DESIGNATION_AND_DIRECTOR_IDENTIFICATION_NUMBER_DIN",
+    "DIGITAL_SIGNATURE_CERTIFICATE_DSC_TIMESTAMP"
+  ]
+}

package/okf/direct_tax/corporate_tax_115baa_115jb/section.json

@@ -0,0 +1,72 @@
+{
+  "sectionId": "ITA1961_SEC115BAA_115JB",
+  "sectionCode": "115BAA-115JB",
+  "aliases": [
+    "115BAA",
+    "115JB",
+    "115JAA",
+    "sec115baa",
+    "sec115jb",
+    "corporate tax",
+    "corporate_tax",
+    "mat",
+    "minimum alternate tax",
+    "concessional corporate tax"
+  ],
+  "governingStatute": "Income-tax Act, 1961 (Act No. 43 of 1961)",
+  "statutorySection": "Sections 115BAA, 115JB and 115JAA",
+  "successorStatute": "Income-tax Act, 2025",
+  "successorSection": "Chapter XI (Corporate Taxation & Special Regimes)",
+  "title": "Tax on income of certain domestic companies (Section 115BAA) and Minimum Alternate Tax (Section 115JB)",
+  "effectivePeriod": {
+    "validFrom": "2019-04-01",
+    "validTo": "OPEN_ENDED",
+    "annualReset": "Annual corporate assessment year determination",
+    "sunsetNotes": "Introduced by Taxation Laws (Amendment) Act, 2019 w.e.f. AY 2020-21. Continues under Income-tax Act, 1961 and transitions to Income-tax Act, 2025."
+  },
+  "plainTextSummary": "Section 115BAA affords domestic corporate assessees an irrevocable option to be taxed at a concessional base rate of 22% plus a flat 10% surcharge and 4% cess (effective 25.168%), subject to foregoing specified exemptions, incentives, and deductions (including Section 10AA, 32(1)(iia), 32AD, 33AB, 35(1)(ii), 35(2AA), 35CCC, 35CCD, and Chapter VI-A deductions other than 80JJAA or 80M). Under Section 115JB(5A), companies opting for Section 115BAA are completely exempt from Minimum Alternate Tax (MAT). However, any accumulated brought-forward MAT credit under Section 115JAA cannot be set off and will lapse. Under the Old Corporate Tax Regime, domestic companies with turnover up to INR 400 Crore in the preceding financial year are taxed at 25% base rate (30% for turnover > 400 Crore), with progressive surcharge (7% for income between 1 Crore and 10 Crore; 12% for income exceeding 10 Crore) and 4% cess. MAT under Section 115JB applies at 15% on adjusted book profits (plus applicable surcharge and cess). Where normal tax exceeds MAT, Section 115JAA allows setting off prior MAT credit up to the difference between normal tax and MAT.",
+  "keyStatutoryThresholds": {
+    "concessionalBaseTaxRate115BAA": 0.22,
+    "concessionalSurchargeRate115BAA": 0.10,
+    "concessionalCessRate115BAA": 0.04,
+    "effectiveTaxRate115BAA": 0.25168,
+    "normalCorporateBaseTaxRateTurnoverUnder400Cr": 0.25,
+    "normalCorporateBaseTaxRateTurnoverOver400Cr": 0.30,
+    "normalSurchargeRate1CrTo10Cr": 0.07,
+    "normalSurchargeRateAbove10Cr": 0.12,
+    "matBaseRateSec115JB": 0.15,
+    "matApplicableUnder115BAA": false,
+    "matCreditForfeitedUnder115BAA": true,
+    "mandatoryElectionForm": "Form 10-IC filed online before the due date specified under Section 139(1)"
+  },
+  "officialCitations": [
+    {
+      "authority": "Income Tax Department, Ministry of Finance",
+      "instrument": "Section 115BAA & Section 115JB, Income-tax Act, 1961",
+      "subject": "Tax on income of certain domestic companies and Minimum Alternate Tax",
+      "officialUrl": "https://www.incometaxindia.gov.in/pages/acts/income-tax-act.aspx"
+    },
+    {
+      "authority": "Central Board of Direct Taxes (CBDT)",
+      "instrument": "Circular No. 29/2019 (Dated 2 October 2019)",
+      "subject": "Clarifications on the provisions of the Taxation Laws (Amendment) Ordinance, 2019 regarding corporate tax rates",
+      "officialUrl": "https://www.incometaxindia.gov.in/communications/circular/circular_29_2019.pdf"
+    },
+    {
+      "authority": "Income Tax Department, Ministry of Finance",
+      "instrument": "Income-tax Rules, 1962 Rule 21AE and Form 10-IC",
+      "subject": "Form 10-IC Application for exercise of option under sub-section (5) of section 115BAA",
+      "officialUrl": "https://www.incometaxindia.gov.in/forms/income-tax-rules/form10-ic.pdf"
+    }
+  ],
+  "requiredDocumentChecklist": [
+    "Audited Financial Statements (Balance Sheet and Profit & Loss Account) under Schedule III of Companies Act, 2013",
+    "Tax Audit Report in Form 3CA/3CD with detailed Annexure for Depreciation under Section 32 and disallowances",
+    "Section 115JB Book Profit Reconciliation Schedule certified by a Chartered Accountant",
+    "Section 115JAA MAT Credit Utilization and Carry-Forward Statement",
+    "Form 10-IC digital filing confirmation and acknowledgement receipt filed prior to Section 139(1) due date",
+    "Board Resolution approving the strategic corporate tax regime election"
+  ],
+  "tier": "PUBLIC_COMMONS_FREE",
+  "version": "2.9.0"
+}

package/okf/direct_tax/special_rates_non_filer_206ab/section.json

@@ -12,15 +12,16 @@
   ],
   "governingStatute": "Income-tax Act, 1961 (Act No. 43 of 1961)",
   "statutorySection": "Section 206AB",
-  "successorStatute": "Income-tax Act, 2025",
-  "successorSection": "Section 397(3)",
-  "title": "Special provision for deduction of tax at source for non-filers of income-tax return",
+  "successorStatute": "Finance Act, 2025 (Statutory Omission)",
+  "successorSection": "Section 206AB Omitted",
+  "title": "Special provision for deduction of tax at source for non-filers of income-tax return (Omitted effective 1 April 2025)",
   "effectivePeriod": {
     "validFrom": "2021-07-01",
-    "validTo": "OPEN_ENDED",
-    "annualReset": "Every assessment year based on preceding FY return filing deadline"
+    "validTo": "2025-03-31",
+    "annualReset": "Annual",
+    "sunsetNotes": "CRITICAL SUNSET: Section 206AB (and Section 206CCA) is formally omitted by the Finance Act, 2025 with effect from 1 April 2025. Post-sunset, tax deductors are relieved from performing portal compliance checks for specified persons, and standard statutory TDS rates apply without non-filer punitive multipliers. Higher rates under Section 206AA (for failure to furnish PAN or inoperative PAN due to non-linkage with Aadhaar) continue independently at 20% (or 5% cap for goods u/s 194Q)."
   },
-  "plainTextSummary": "Where tax is required to be deducted at source on any sum paid or payable to a specified person (a person who has not filed their ITR for the preceding financial year and has aggregate TDS/TCS of ₹50,000 or more in said year), the tax shall be deducted at the higher of: (i) twice the rate specified in the relevant Act, (ii) twice the rate in force, or (iii) 5%. If Section 206AA (no-PAN) also applies, tax is deducted at the higher of 206AA or 206AB rates. Does NOT apply to non-residents without a PE in India, or to Sections 192, 192A, 194B, 194BA, 194BB, 194-IA, 194-IB, 194M, 194N.",
+  "plainTextSummary": "Where tax was required to be deducted at source prior to 1 April 2025 on any sum paid or payable to a specified person (a person who had not filed their ITR for the preceding financial year and had aggregate TDS/TCS of ₹50,000 or more in said year), tax was deducted at the higher of: (i) twice the rate specified in the relevant Act, (ii) twice the rate in force, or (iii) 5%. Effective 1 April 2025, Section 206AB was formally omitted by the Finance Act, 2025. For deductions on or after 1 April 2025, Section 206AB is obsolete and standard TDS rates apply. Higher rates under Section 206AA for invalid/missing PAN remain fully active.",
   "keyStatutoryThresholds": {
     "priorYearAggregateTdsTcsThresholdInr": 50000,
     "penaltyMultiplier": "Twice the applicable rate or 5%, whichever is higher",

package/okf/indirect_tax_gst/export_services_lut_sec16/circulars/cbic_circular_161_2021_intermediary_clarification.md

@@ -0,0 +1,37 @@
+---
+id: cbic_circular_161_2021_intermediary_clarification
+title: CBIC Circular No. 161/17/2021-GST - Clarification on Intermediary Services and Export of Services
+authority: Central Board of Indirect Taxes and Customs (CBIC), Department of Revenue, Ministry of Finance
+date: 2021-09-20
+statutory_section: IGST Section 16 read with Section 2(6) and Section 13(8)(b)
+valid_from: 2021-09-20
+valid_to: OPEN_ENDED
+temporal_status: ACTIVE
+subject: Clarification relating to export of services and scope of intermediary services under Section 13(8)(b)
+official_url: https://taxinformation.cbic.gov.in/view-pdf/1003051/ENG/Circulars
+---
+
+> [STATUTORY VALIDITY WINDOW & TEMPORAL STATUS]  
+> **Valid From**: 20 September 2021  
+> **Valid To**: OPEN_ENDED  
+> **Temporal Status**: ACTIVE  
+> **Governing Sections**: Section 16, Section 2(6), Section 13(2), Section 13(8)(b) of the IGST Act, 2017  
+
+# CBIC Circular No. 161/17/2021-GST: Clarifications on Intermediary Services
+
+## 1. Statutory Background
+Section 2(13) of the Integrated Goods and Services Tax Act, 2017 defines an "intermediary" as a broker, an agent or any other person, by whatever name called, who arranges or facilitates the supply of goods or services or both, or securities, between two or more persons, but does not include a person who supplies such goods or services or both or securities on his own account.
+
+Under Section 13(8)(b) of the IGST Act, the place of supply for intermediary services is deemed to be the location of the supplier. Consequently, even if the service recipient is located outside India and payment is received in convertible foreign exchange, the transaction fails condition (iii) of Section 2(6) (which mandates that the place of supply must be outside India), and therefore cannot qualify as a zero-rated export of service under Section 16.
+
+## 2. Key Tests to Determine Intermediary vs Principal
+The Circular establishes four definitive prerequisites before a service provider can be categorized as an intermediary:
+1. **Minimum Three Parties**: An intermediary does not participate in the core supply of goods/services directly to the recipient on its own account, but arranges or facilitates the main supply between two other distinct principals.
+2. **Two Distinct Supplies**: There must exist (a) the main supply between the two principals, and (b) the ancillary supply of arrangement/facilitation provided by the intermediary to one of the principals.
+3. **Character of Agent/Broker**: The intermediary acts in an agency or facilitator capacity without altering the nature or value of the underlying service.
+4. **Exclusion of Services on Own Account**: Where the service provider supplies software development, IT services, back-office data processing, or engineering design directly to an overseas client on a principal-to-principal basis, it supplies services on its own account. Sub-contracting of services on a principal-to-principal basis is NOT an intermediary service.
+
+## 3. Impact on Zero-Rated Export Eligibility under LUT
+1. If the entity provides services on its own account directly to the foreign client, the place of supply is determined under the default rule of Section 13(2) (location of recipient outside India), satisfying all five conditions of Section 2(6).
+2. The supply is zero-rated under Section 16(1)(a) and can be exported without payment of IGST under a valid Letter of Undertaking (LUT) in Form GST RFD-11.
+3. The exporter retains full statutory entitlement to claim refund of unutilized input tax credit under Section 54(3) of the CGST Act.

package/okf/indirect_tax_gst/export_services_lut_sec16/forms/lut_form_gst_rfnd_11_declaration.json

@@ -0,0 +1,58 @@
+{
+  "formCode": "FORM_GST_RFD_11",
+  "title": "Furnishing of Letter of Undertaking (LUT) for Export of Goods or Services",
+  "statutoryBasis": "Section 16 of IGST Act, 2017 read with Rule 96A of CGST Rules, 2017",
+  "schema": {
+    "exporterParticulars": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "legalName": { "type": "string", "required": true },
+        "tradeName": { "type": "string", "required": false },
+        "gstin": { "type": "string", "pattern": "^[0-9]{2}[A-Z]{5}[0-9]{4}[A-Z]{1}[1-9A-Z]{1}Z[0-9A-Z]{1}$", "required": true },
+        "pan": { "type": "string", "pattern": "^[A-Z]{5}[0-9]{4}[A-Z]{1}$", "required": true },
+        "financialYear": { "type": "string", "pattern": "^20[0-9]{2}-20[0-9]{2}$", "required": true },
+        "lutArn": { "type": "string", "required": true }
+      }
+    },
+    "exportDeclarationDetails": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "exportType": { "type": "string", "enum": ["SERVICES", "GOODS", "SEZ_SUPPLIES"], "required": true },
+        "zeroRatedUnderLut": { "type": "boolean", "required": true },
+        "recipientLocation": { "type": "string", "required": true },
+        "currencyOfInvoice": { "type": "string", "pattern": "^[A-Z]{3}$", "required": true },
+        "isIntermediaryService": { "type": "boolean", "required": true },
+        "statutoryEndorsementText": {
+          "type": "string",
+          "enum": [
+            "SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX"
+          ],
+          "required": true
+        }
+      }
+    },
+    "forexRealizationUndertaking": {
+      "type": "object",
+      "required": true,
+      "properties": {
+        "maxRealizationPeriodMonths": { "type": "number", "default": 12, "required": true },
+        "fircOrEbrcRequired": { "type": "boolean", "default": true, "required": true },
+        "interestPayableUnderSection50": { "type": "number", "default": 18.0, "required": true }
+      }
+    },
+    "witnessSignatures": {
+      "type": "array",
+      "minItems": 2,
+      "items": {
+        "type": "object",
+        "properties": {
+          "name": { "type": "string", "required": true },
+          "occupation": { "type": "string", "required": true },
+          "address": { "type": "string", "required": true }
+        }
+      }
+    }
+  }
+}

package/okf/indirect_tax_gst/export_services_lut_sec16/section.json

@@ -0,0 +1,66 @@
+{
+  "sectionId": "IGST2017_SEC16_LUT",
+  "sectionCode": "IGST-SEC-16-LUT",
+  "aliases": [
+    "IGST-16",
+    "sec16",
+    "lut",
+    "export lut",
+    "zero rated export",
+    "zero_rated",
+    "export of services",
+    "place of supply export",
+    "section 2(6) export"
+  ],
+  "governingStatute": "Integrated Goods and Services Tax Act, 2017 (Act No. 13 of 2017)",
+  "statutorySection": "Section 16 read with Section 2(6) and Section 13",
+  "successorStatute": "Integrated Goods and Services Tax Act, 2017 (In Force)",
+  "successorSection": "Section 16",
+  "title": "Zero rated supply and export of services under Letter of Undertaking (LUT)",
+  "effectivePeriod": {
+    "validFrom": "2017-07-01",
+    "validTo": "OPEN_ENDED",
+    "annualReset": "LUT ARN renewed annually before 31st March for the upcoming financial year",
+    "sunsetNotes": "Permanent zero-rating provision under IGST Act, 2017."
+  },
+  "plainTextSummary": "Under Section 16(1) of the IGST Act, zero-rated supply includes export of goods or services, or supplies to a Special Economic Zone (SEZ) developer or unit. Section 16(3) read with Rule 96A of the CGST Rules permits a registered person to export goods or services without payment of integrated tax (IGST) after furnishing a Letter of Undertaking (LUT in Form GST RFD-11). To qualify as an export of services under Section 2(6), five cumulative conditions must be satisfied: (1) supplier of service is located in India, (2) recipient of service is located outside India, (3) place of supply of service is outside India (determined under Section 13), (4) payment has been received in convertible foreign exchange or in Indian rupees wherever permitted by the Reserve Bank of India, and (5) supplier and recipient are not merely establishments of distinct persons. If any condition fails—such as intermediary services under Section 13(8)(b) where the place of supply is deemed to be the location of the supplier in India—zero-rating is denied and standard IGST applies. Exporters under LUT are entitled to claim a refund of unutilized Input Tax Credit (ITC) under Section 54(3).",
+  "keyStatutoryThresholds": {
+    "zeroRatedIgstTaxRateUnderLut": 0.0,
+    "cumulativeExportConditionsCount": 5,
+    "lutRenewalRequirement": "Annual renewal on GST portal in Form GST RFD-11 for each financial year",
+    "forexRealizationWindowMonths": 12,
+    "itcRefundEntitlement": "Full refund of accumulated unutilized ITC under Section 54(3) of CGST Act",
+    "intermediaryServiceDisqualification": "Intermediary services u/s 13(8)(b) have place of supply in India, disqualifying them from zero-rated export",
+    "gstrReportingTable": "GSTR-1 Table 6A (Export invoices without payment of tax)"
+  },
+  "officialCitations": [
+    {
+      "authority": "Central Board of Indirect Taxes and Customs (CBIC)",
+      "instrument": "Section 16 & Section 2(6), Integrated Goods and Services Tax Act, 2017",
+      "subject": "Zero rated supply and definition of export of services",
+      "officialUrl": "https://taxinformation.cbic.gov.in/view-pdf/1003051/ENG/Circulars"
+    },
+    {
+      "authority": "Central Board of Indirect Taxes and Customs (CBIC)",
+      "instrument": "Circular No. 161/17/2021-GST (Dated 20 September 2021)",
+      "subject": "Clarification relating to export of services and scope of intermediary services under Section 13(8)(b)",
+      "officialUrl": "https://taxinformation.cbic.gov.in/view-pdf/1003051/ENG/Circulars"
+    },
+    {
+      "authority": "Goods and Services Tax Network (GSTN)",
+      "instrument": "Form GST RFD-11 & Rule 96A of CGST Rules, 2017",
+      "subject": "Furnishing of Letter of Undertaking for export of goods or services without payment of integrated tax",
+      "officialUrl": "https://www.gst.gov.in/help/returns"
+    }
+  ],
+  "requiredDocumentChecklist": [
+    "Active Letter of Undertaking (LUT) acknowledgement receipt (ARN) for the financial year",
+    "Export Invoices clearly endorsing 'SUPPLY MEANT FOR EXPORT UNDER LUT WITHOUT PAYMENT OF INTEGRATED TAX'",
+    "Foreign Inward Remittance Certificate (FIRC) or Electronic Bank Realisation Certificate (e-BRC)",
+    "Service Level Agreement (SLA) or Master Services Agreement with foreign client proving non-intermediary status",
+    "GSTR-1 Table 6A and GSTR-3B monthly filing reconciliation",
+    "Form GST RFD-01 refund application with electronic statement of invoices and inward remittances"
+  ],
+  "tier": "PUBLIC_COMMONS_FREE",
+  "version": "2.9.0"
+}

package/okf/international_tax/foreign_exchange_indas_21_109/circulars/mca_indas_21_foreign_exchange_rates.md

@@ -0,0 +1,39 @@
+---
+id: mca_indas_21_foreign_exchange_rates
+title: MCA Companies (Indian Accounting Standards) Rules, 2015 - Ind AS 21 & Ind AS 109
+authority: Ministry of Corporate Affairs (MCA), Government of India
+date: 2015-02-16
+statutory_section: Ind AS 21 read with Ind AS 109
+valid_from: 2016-04-01
+valid_to: OPEN_ENDED
+temporal_status: ACTIVE
+subject: Prescribed accounting treatment for foreign exchange revaluations and hedge accounting
+official_url: https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/accounting-standards.html
+---
+
+> [STATUTORY VALIDITY WINDOW & TEMPORAL STATUS]  
+> **Valid From**: 1 April 2016  
+> **Valid To**: OPEN_ENDED  
+> **Temporal Status**: ACTIVE  
+> **Governing Standards**: Ind AS 21, Ind AS 109, and Schedule III to the Companies Act, 2013  
+
+# Ind AS 21 & Ind AS 109: Foreign Exchange Accounting and Hedge Accounting
+
+## 1. Scope and Classification of Foreign Currency Balances
+Under Ind AS 21 (The Effects of Changes in Foreign Exchange Rates), an entity must classify foreign currency denominated assets and liabilities into two distinct categories at each financial reporting date:
+1. **Monetary Items**: Units of currency held and assets and liabilities to be received or paid in a fixed or determinable number of units of currency (e.g., trade receivables, trade payables, loans, cash and bank balances).
+2. **Non-Monetary Items**: Items that do not carry a right to receive, or an obligation to deliver, a fixed or determinable number of units of currency (e.g., property, plant and equipment, intangible assets, inventories, prepaid expenses).
+
+## 2. Reporting at Subsequent Reporting Dates (Ind AS 21.23)
+- Foreign currency monetary items must be retranslated using the **closing spot exchange rate** at the balance sheet date.
+- Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the exchange rate at the date of the transaction and are **never retranslated**.
+- Non-monetary items measured at fair value in a foreign currency are translated using the exchange rates at the date when the fair value was determined.
+
+## 3. Recognition of Exchange Differences (Ind AS 21.28)
+Exchange differences arising on the settlement of monetary items or on translating monetary items at rates different from those at which they were translated on initial recognition during the period or in previous financial statements must be recognized in **Profit or Loss (P&L)** in the period in which they arise.
+
+## 4. Cash Flow Hedge Accounting Exception (Ind AS 109.6.5)
+Where an entity enters into derivative contracts (e.g., foreign exchange forwards) and designates them in a qualifying cash flow hedge of forecast foreign currency sales:
+1. The **effective portion** of the gain or loss on the hedging instrument is recognized directly in **Other Comprehensive Income (OCI)** and accumulated under equity in the Cash Flow Hedge Reserve.
+2. The **ineffective portion** is recognized immediately in **Profit or Loss**.
+3. Upon realization of the forecasted underlying transaction, the accumulated reserve in OCI is reclassified to profit or loss.