Carry forward and set off of losses: predecessor tax attributes deemed to successors, conditional on continuity and asset retention. Carry forward and set off rules deem accumulated loss and unabsorbed depreciation of a predecessor entity to be those of the successor in specified amalgamations, demergers and business reorganisations, subject to caps for erstwhile public sector companies, continuity and asset value retention conditions to ensure genuine revival, apportionment rules for demergers, deeming for firm-to-company and company-to-LLP successions, and consequences treating disallowed set offs as income on non compliance; definitions and transitional carry forward limits for post specified date reorganisations are provided.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Carry forward and set off of losses: predecessor tax attributes deemed to successors, conditional on continuity and asset retention.
Carry forward and set off rules deem accumulated loss and unabsorbed depreciation of a predecessor entity to be those of the successor in specified amalgamations, demergers and business reorganisations, subject to caps for erstwhile public sector companies, continuity and asset value retention conditions to ensure genuine revival, apportionment rules for demergers, deeming for firm-to-company and company-to-LLP successions, and consequences treating disallowed set offs as income on non compliance; definitions and transitional carry forward limits for post specified date reorganisations are provided.
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