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Microlesson · 5-min read

AS 22 — Tax Rates, Tax Holiday (Sections 80IA/80IB) and MAT

## Tax Rates, Tax Holiday, and MAT

### Which Tax Rate to Use?

Tax ComponentRate to Apply
Current TaxRate applicable to the current period
Deferred TaxFuture rate if announced/proposed by government in the current year; otherwise current year's rate

Example:

Year 2024-25: current rate = 30%.

Budget 2024 proposes 35% for future years.

→ Current Tax: 30% | Deferred Tax: 35%

Using the correct future rate for deferred tax ensures the balance sheet reflects what will actually be paid when the timing difference reverses.

---

### Tax Holiday — Sections 80IA / 80IB

Certain companies enjoy a tax holiday under Sections 80IA or 80IB (e.g., infrastructure companies, new industrial units). During the holiday, income is exempt from tax.

The problem: A timing difference originating before the holiday might reverse during the holiday — when no tax is payable anyway. Creating a DTA for that reversal is meaningless.

AS 22 Rule:

> DTA in respect of timing differences that reverse during the tax holiday period should NOT be recognised.

FIFO Rule for Reversals:

> Timing differences that originate first are considered to reverse first (in chronological order).

Apply the FIFO rule to determine in which periods reversals fall. Only recognise DTA for the portion whose reversal falls outside the tax holiday period.

Timeline Illustration:

```

Periods: 1 2 3 4 5 6 7

Status: [HOL][HOL][HOL][TAX][TAX][TAX][TAX]

```

If a timing difference originates in Period 1 and reverses in Periods 2 and 3 (both still holiday) → no DTA.

If reversal extends into Period 4 onwards (taxable period) → DTA for only that portion.

---

### MAT (Minimum Alternate Tax) — Section 115JB

Where a company is subject to MAT:

  • Compute Normal Tax (taxable profit × normal rate)
  • Compute MAT (book profit × MAT rate, e.g. 7.5%)
  • Current Tax = whichever is higher
  • Deferred Tax is still calculated on normal tax timing differences using the normal rate
ItemValue
Taxable profit × 20%= Normal Tax
Book profit × 7.5%= MAT
Current Tax= Higher of the two
Deferred TaxComputed on timing differences @ 20% (normal rate only)

Worked example

### Example 1

### Tax Rate Change: Future Rate Already Proposed (Year 2024-25)

Current rate: 30%. Government proposes 35% for future years in Budget 2024.

ComponentRateBasis
Current Tax30%This year's applicable rate
Deferred Tax35%Future rate (proposed in current year)

If timing difference = ₹1,00,000:

  • Current Tax calculation: ₹1,00,000 × 30% (as part of taxable profit)
  • DTL on that timing difference: ₹1,00,000 × 35% = ₹35,000 (not ₹30,000)

Using the wrong rate (30%) would under-state the future liability by ₹5,000.

### Example 2

### Tax Holiday — Recognising Only Eligible DTA

Company has a tax holiday for the first 3 periods. Timing difference of ₹200 originates in Period 1, reversing ₹40 per period over 5 periods (Periods 2–6). Tax rate 40%.

PeriodHoliday?ReversalDTA Recognised?
1Yes (origin)
2Yes₹40NO
3Yes₹40NO
4No₹40Yes ₹16
5No₹40Yes ₹16
6No₹40Yes ₹16

Total DTA recognised = ₹120 × 40% = ₹48 (only the part reversing in taxable years).

DTA NOT recognised = ₹80 × 40% = ₹32 (reversals during holiday are worthless).

### Example 3

### MAT vs. Normal Tax — Current Tax Determination

MetricCalculationAmount
Taxable profit₹60,000
Normal Tax @ 20%60,000 × 20%₹12,000
Book profit₹3,50,000
MAT @ 7.5%3,50,000 × 7.5%₹26,250
Current Tax (higher)₹26,250

Deferred Tax is still computed separately using timing differences and the 20% normal rate. MAT only affects current tax, not deferred tax.

⚠️ Common exam mistakes

  • Using the current year rate for deferred tax when the government has already announced a future rate — always check Budget announcements
  • Recognising DTA for timing differences whose reversals fall entirely within the tax holiday period — those reversals produce no tax saving
  • Applying the FIFO rule incorrectly — the earliest originating timing differences are assumed to reverse first, not the largest or most recent
  • Treating MAT as relevant to deferred tax calculation — MAT affects only current tax; deferred tax always uses the normal income tax rate and provisions
Bare-Act text Para 27 — Tax Holiday (Sections 80IA and 80IB of the Income Tax Act, 1961) · AS 22 — Accounting for Taxes on Income · click to expand
Deferred tax in respect of timing differences which reverse during the tax holiday period should not be recognised to the extent the enterprise's gross total income is subject to the deduction during the tax holiday period under those sections. For the above purpose, timing differences which originate first shall be considered to reverse first.
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