2022 (7) TMI 431

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.... Revenue by: Shri Y. V. S. T. Sai , CIT-DR ORDER PER K. NARASIMHA CHARY , JM : Aggrieved by the order dated 20/06/2018, passed by the Learned Commissioner of Income Tax (Appeals)-1, Hyderabad ("Ld. CIT(A)") in the case of M/s. Aster Rail Private Limited ("the assessee") for the AY.2014-15, assessee filed this appeal. 2. Brief facts of the case are that the assessee M/s Aster Rail Pr....

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....d that they change in the shareholding took place pursuant to the agreement dated 30/07/2013, the payment in respect of which was made in the month of August 2013 and, therefore, only the brought forward losses are not entitled to be carried forward in the case of changes in the shareholding but not the current year losses. Ld. CIT(A), however, observed that the entire process of transition was co....

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....-13 are not entitled to be carried forward and set off against the current year income but this section does not prevent the carry forward of the current year losses to the future. 5. Ld. DR placing reliance on the orders of the authorities below and argued on the lines of reasoning given by them. 6. We have gone through the record in the light of the submissions made on either side. Insofar....

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....nt assessment year is 2014-15. With reference to these, the losses that are not allowable to be carried forward to be set off against the income of the assessment year 2014-15 or the losses relating to the period prior to the assessment year 2014-15. It means that any loss that is coming from the assessment year 2013-14 is not allowable against the income of the assessment year 2014-15. This does ....