Section 72A - Provisions relating to carry forward and set off of accumulated loss and unabsorbed depreciation allowance in amalgamation or demerger, etc.

Carry forward of accumulated losses in restructurings hinges on continuity, asset retention and genuine business purpose compliance.

Section 72A deems accumulated loss and unabsorbed depreciation of a predecessor entity to be those of the successor on amalgamation, demerger or specified reorganisations, subject to conditions requiring continuity of business and substantial retention of book value of fixed assets, with failure to meet those conditions resulting in earlier set offs being treated as taxable income; demerger rules allow direct transfer or proportionate apportionment of losses, and special provisions govern successor treatment and limited carry forward periods for later restructurings.