Section 64
Section 64: deductions on business reorganisation of co-operative banks
Section 64 is a narrow, technical provision for co-operative banks that go through an amalgamation, demerger or conversion (collectively "business reorganisation") partway through a tax year. It splits certain deductions - under Sections 33, 44 and 52(1) (Table Sl. Nos. 1 or 2) - between the predecessor bank and the successor bank/converted banking company on a time-apportioned basis.
This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.
What Section 64 covers
Section 64(1) applies the special rules of this section wherever a business reorganisation of a co-operative bank has taken place during the tax year, for deductions otherwise available under Section 33, Section 44, or Section 52(1) (Table Sl. No. 1 or 2).
The time-apportionment formula
Section 64(2) splits the deduction that would have been available to the predecessor bank (if reorganisation had not happened) between the predecessor and the successor, based on the number of days each entity carried on the business during the tax year:
- Predecessor co-operative bank's share = A × B ÷ C
- Successor co-operative bank's (or converted banking company's) share = A × D ÷ C
- Where A = the deduction that would have been allowable to the predecessor bank if there had been no reorganisation; B = number of days from the start of the tax year to the day before the reorganisation; C = total number of days in the tax year; D = number of days from the date of reorganisation to the end of the tax year.
Continuity of Section 44 / 52(1) benefits after reorganisation
Section 64(3) provides that where an undertaking of the predecessor bank, entitled to deduction under Section 44 or Section 52(1) (Table Sl. No. 1 or 2), is transferred to a successor bank or converted banking company because of business reorganisation, that section continues to apply to the successor in the tax years after the reorganisation, exactly as it would have applied to the predecessor if the reorganisation had not taken place.
Frequently asked questions
Which co-operative bank deductions does Section 64 affect?
Deductions available under Section 33, Section 44, or Section 52(1) (Table Sl. No. 1 or 2), where a business reorganisation happens during the tax year.
How is the deduction split between predecessor and successor bank?
Time-apportioned by number of days: the predecessor gets the deduction multiplied by the days before reorganisation over total days in the year, and the successor gets the deduction multiplied by the days after reorganisation over total days in the year, per the formula in Section 64(2).
Related sections
Want this applied to your actual filing, not just explained?
Get expert help on co-operative bank reorganisation tax treatmentLast updated 9 September 2026