Assessee Entitled to Set-Off Losses Despite Shareholding Change; Section 79 Provisions Deemed Inapplicable Due to No Management Shift.

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....Set off of brought forward losses denied - change in the shareholding pattern of the assessee post merger - Considering the fact that the assessee is a subsidiary of TRIL, Actis and THPL before merger and after merger still a subsidiary of TRIL. It was brought to our notice that as on 31.03.2014 TRIL holds 100% shares of the assessee-company. In our considered view, effectively there is no change in the management as well as voting rights in the assessee-company. - Provisions of section 79 not applicable - appellant is entitled to set off the business loss brought forward from earlier years - AT....