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    <title>2026 (3) TMI 681 - ITAT DELHI</title>
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    <description>Brought-forward business losses must be set off against current-year business income before unabsorbed depreciation, which is treated as current-year depreciation. Denial of set-off based on a change in shareholding is invalid where it relies on an incorrect relevant date and is raised without the required enhancement notice. Amounts written back are not taxable as deemed income where the related provisions were disallowed in earlier years, and capital creditors are not covered because they were never claimed as deductions. The stated position supports rectification of the set-off and deletion of additions on such write-backs.</description>
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