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Income-tax Act, 2025 | Section 64

Section 64 - Special provision for computing deductions in case of business reorganisation of co-operative banks

In a co-operative-bank reorganisation, specified deductions are apportioned between predecessor and successor to preserve continuity and prevent double claims.

Reviewed by CA Nikhil Gupta · Updated 9 October 2026

Section 64: operativeEffective 1 April 2026Tax Year 2026-27 onwardReviewed 8 October 2026
Current-law control

Section 64 is presented using the consolidated Income-tax Act, 2025 as amended by the Finance Act, 2026. The general commencement date is 1 April 2026. Earlier years and saved proceedings may remain governed by the Income-tax Act, 1961 and the repeal/savings framework.

2-minute professional decode

In a co-operative-bank reorganisation, specified deductions are apportioned between predecessor and successor to preserve continuity and prevent double claims.

Professional checkpoint: Apply the provision only after checking the defined person, tax year, evidence, thresholds and any connected Rule or Schedule.

Who should test this section?

Section 64 should be tested by businesses, professionals, non-residents and advisers whenever the computation touches special provision for computing deductions in case of business reorganisation of co-operative banks; the special rule must be checked before the ordinary business-profit machinery is applied.

Evidence to retain

For section 64, retain the contracts, ledgers, invoices, banking evidence, prescribed reports and computation papers that specifically prove the factual trigger and quantum for special provision for computing deductions in case of business reorganisation of co-operative banks.

1961 Act bridge

Legacy provisionLegacy headingMapping
No direct one-to-one legacy section mapped in the comparison register.

The bridge is a research aid. Legacy case law carries over only after the current wording and transition rules are matched.

Rules and forms linked to this section

No provision-specific Rule was independently mapped from the current Rules register for this section. That does not mean the wider Rules are irrelevant.

Worked application

Prepare a hypothetical transaction involving special provision for computing deductions in case of business reorganisation of co-operative banks. Identify the person, tax year, trigger, evidence and connected provision first; then apply section 64 step-by-step and document why each statutory condition is or is not met.

Common mistake

A recurring section 64 error is to carry the book or ordinary tax treatment into special provision for computing deductions in case of business reorganisation of co-operative banks without first testing the provision-specific override, eligibility conditions and linked Rule/Form requirements.

Compliance approach

Identify the statutory trigger for section 64, lock the relevant tax year, reconcile the facts to the operative sub-section, preserve the evidence trail and separately test every linked Rule, Form, Schedule and exception before finalising the return position.

Numeric / timing checkpoints in the operative text

Related provisions

Current statutory text

64. (1) The deduction under section 33 or 44 or 52(1) (Table: Sl. No. 1 or 2) shall, in a case where business reorganisation of a co-operative bank has taken place during the tax year, be allowed as per provisions of this section. (2) The amount of deduction allowable to the predecessor co-operative bank or to the successor co-operative bank or to the converted banking company under section 33 or 44 or 52(1) (Table: Sl. No. 1 or 2)shall be determined as per the formula— (i) for predecessor co-operative bank:— A×B C (ii) for successor co-operative bank or converted banking company:— A×D C where,— A = the amount of deduction allowable to the predecessor co-operative bank, if the business reorganisation had not taken place; B = the number of days comprised in the period beginning with the 1st day of the tax year and ending on the day immediately preceding the date of business reorganisation; and C = the total number of days in the tax year in which the business reorgani- sation has taken place. D = the number of days comprised in the period beginning with the date of business reorganisation and ending on the last day of the tax year. (3) The provisions of section 44 or 52(1) (Table: Sl. No. 1 or 2) shall, in a case where an undertaking of the predecessor co-operative bank entitled to the deduc- tion under the said section is transferred before the expiry of the period specified therein to a successor co-operative bank or to a converted banking company on account of business reorganisation, apply to the successor co-operative bank or to the converted banking company in the tax years subsequent to the year of business reorganisation as they would have applied to the predecessor co-operative bank, as if the business reorganisation had not taken place.

Primary-source trail

Source status: full Section 64 statutory text in the local source corpus; reconciled to the current consolidated Act control on 8 October 2026.

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