https://www.taxtmi.com/highlights?id=98824 The Kerala Agricultural Income Tax Act, 1991 does not allow an amalgamated company to treat the amalgamating company's losses as its own for set-off. Section 12 permits carry forward only by the person who actually sustained the loss, and Section 54 on succession to business deals with assessment and recovery of dues, not transfer of loss relief to the successor. The scheme of amalgamation could not create a tax benefit absent in the statute. In any event, the claimed losses for the relevant year were beyond the eight-year carry-forward limit under Section 12, so the set-off was barred. The appeals were dismissed. en-us Wed, 15 Apr 2026 09:05:03 +0530 Wed, 15 Apr 2026 09:05:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98824 The Kerala Agricultural Income Tax Act, 1991 does not allow an amalgamated company to treat the amalgamating company's losses as its own for set-off. Section 12 permits carry forward only by the person who actually sustained the loss, and Section 54 on succession to business deals with assessment and recovery of dues, not transfer of loss relief to the successor. The scheme of amalgamation could not create a tax benefit absent in the statute. In any event, the claimed losses for the relevant year were beyond the eight-year carry-forward limit under Section 12, so the set-off was barred. The appeals were dismissed. Highlights Income Tax Wed, 15 Apr 2026 09:05:03 +0530 https://www.taxtmi.com/highlights?id=98824