Prohibition on loss set-off prevents adjustment of undisclosed income detected through search, requisition, or specified survey proceedings.

Undisclosed income arising from a search, requisition or specified survey cannot be reduced by brought-forward or current-year losses, losses under any head, or unabsorbed depreciation under section 120 of the Income Tax Act, 2025. Such income includes undisclosed assets, entries, documents, transactions, or incorrect claims concerning the block period. The preceding section 79A regime likewise denied set-off against undisclosed income found through search, requisition, or non-TDS/TCS survey, including unrecorded income and false expense entries detected through those proceedings.

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