Change in Beneficial Ownership Affects Loss Carry Forward u/s 79 of Income Tax Act Despite Common Holding Company.

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....Carry forward and set off of brought forward losses - Section 79 - there is a change of the beneficial ownership of shares because the predecessor and successor companies are distinct from each other, and the factum of they being subsidiaries of the ultimate holding company, does not mean that there is no change in the beneficial interest - AT....