Set-off of Prior Year Losses Against Current Income: Section 79's 51% Shareholding Rule May Not Apply.

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....Set off of loss brought forward losses - conditions of 51% shareholding - the assessee is not seeking carry forward of losses to be set off but the assessee is seeking to set off the brought forward losses of the earlier years to be set off in the current assessment year and therefore provisions of section 79 may not be applicable - AT....