(1)Where a foreign company is engaged in the business of banking in India through its branch situated in India and such branch is converted into a subsidiary Indian company as per the scheme framed by the Reserve Bank of India, then, irrespective of anything contained in this Act and subject to the conditions as may be notified by the Central Government,—(a)the capital gains arising from such conversion shall not be chargeable to tax in the tax year in which such conversion takes place; and(b)the provisions of this Act relating to––(i)treatment of unabsorbed depreciation, set off or carry forward and set off of losses;(ii)tax credit in respect of tax paid on deemed income relating to certain companies; and(iii)computation of income of the foreign company and subsidiary Indian company,shall apply with such exceptions, modifications and adaptations as specified in that notification.
