{"id":386093,"date":"2026-06-04T09:00:53","date_gmt":"2026-06-04T03:30:53","guid":{"rendered":"https:\/\/www.scconline.com\/blog\/?p=386093"},"modified":"2026-06-03T18:40:20","modified_gmt":"2026-06-03T13:10:20","slug":"section-79-income-tax-act-carry-forward-losses-analysis","status":"publish","type":"post","link":"https:\/\/www.scconline.com\/blog\/post\/2026\/06\/04\/section-79-income-tax-act-carry-forward-losses-analysis\/","title":{"rendered":"Insights into section 79, Income Tax Act: Disallowances on Carry Forward of Loss"},"content":{"rendered":"
\n

The interplay between Sections 72-A and 79 becomes highly relevant during corporate reorganisations like mergers, acquisitions, and demergers involving closely held companies, as these events inherently involve a change in shareholding.<\/p>\n

Introduction to Section 72-A<\/h2>\n

Under the general principles of income tax jurisprudence, the right to carry forward and set off business losses and unabsorbed depreciation is vested strictly in the entity that incurred them. Section 72-A<\/a><\/span> <\/span>acts as a significant exception to this rule.<\/span><\/p>\n

Introduced to encourage corporate restructuring and the revival of financially distressed companies, Section 72-A allows the carry forward and set off of accumulated losses and unabsorbed depreciation of an amalgamating company (the predecessor) by the amalgamated company (the successor) in cases of amalgamation or demerger.<\/p>\n

Introduction to Section 79<\/h2>\n

While Section 72-A is an enabling provision, Section 79<\/a><\/span> <\/span>is a restrictive, anti-abuse provision. It applies specifically to closely held companies (companies in which the public is not substantially interested).<\/span><\/p>\n

Section 79 restricts the carry forward and set off of business losses if there is a significant change in the company’s shareholding. Specifically, the law mandates that the shares carrying at least 51 per cent of the voting power on the last day of the year, in which the loss is sought to be set off, must be held by the same persons who beneficially held at least 51 per cent of the voting power on the last day of the financial year in which the loss was originally incurred.<\/p>\n

The primary objective of Section 79 is to prevent the practice of “buying losses”— where profitable entities acquire loss-making closely held companies purely to utilise their accumulated losses to reduce their own tax liabilities.<\/p>\n

The interplay between Sections 72-A and 79<\/h2>\n

The interplay between Sections 72-A and 79 becomes highly relevant during corporate reorganisations like mergers, acquisitions, and demergers involving closely held companies, as these events inherently involve a change in shareholding.<\/p>\n

Here is, how the two sections interact:<\/p>\n

1. The “specific” versus “general” rule<\/span>: Section 72-A is a specific code for amalgamations and demergers, while Section 79 is a general provision regarding changes in shareholding. When a restructuring qualifies as a valid amalgamation under Section 72-A, the law explicitly fictionally treats the accumulated losses of the amalgamating company as the losses of the amalgamated company for the previous year in which the amalgamation took place.<\/p>\n

2. Section 79 exceptions for restructuring<\/span>: To harmonise the two sections, the legislature has provided specific carve-outs within Section 79. For instance, the restrictions of Section 79 do not apply if a change in the voting power takes place consequent upon:<\/p>\n

(a<\/span>) The death of a shareholder or by way of gift to a relative.<\/p>\n

(b<\/span>) A resolution plan approved under the Insolvency and Bankruptcy Code, 2016 (IBC)<\/a> (subject to jurisdictional hearing).<\/p>\n

(c<\/span>) Changes in shareholding of an Indian company resulting from the demerger of a foreign company (subject to certain conditions).<\/p>\n

3. Subsequent changes in shareholding post-<\/span>amalgamation<\/span>: If a closely held company inherits losses via an amalgamation under Section 72-A, those losses effectively become a fresh slate of losses for the amalgamated company. However, if the amalgamated company itself undergoes a further change in shareholding in subsequent years, Section 79 will be triggered. The amalgamated company must then ensure that 51 per cent of its voting power remains intact compared to the year the amalgamation took place, to continue setting off those inherited losses.<\/p>\n

In summary, Section 72-A facilitates business consolidation by allowing the transfer of tax losses under strict operational conditions, while Section 79 acts as a gatekeeper to ensure that the ultimate ownership of closely held companies remains substantially the same, preventing the commercialisation of tax losses.<\/p>\n

This comprehensive article will serve as a master blueprint for corporate taxpayers and direct tax litigators facing a potential disallowance of brought forward losses. Rather than treating Section 79 as a strict, mechanical barrier, this article will deconstruct the provision to reveal a multi-tiered defence strategy spanning statutory interpretation, procedural boundaries, and intersecting corporate laws.<\/p>\n

Key themes<\/h2>\n

1. Tier 1: The substantive defence (Piercing the veil and statutory carve-outs)<\/span><\/p>\n

(a<\/span>) Beneficial versus registered ownership: Analysing how courts differentiate between mere changes in the registered shareholding pattern and the continuity of ultimate “beneficial voting power” during corporate restructurings and internal mergers. These cases explore whether internal reorganisations, holding company changes, or shifts in immediate registered shareholding trigger Section 79 if the ultimate beneficial voting power remains with the same group.<\/p>\n

(i<\/span>) CIT<\/span> v. AMCO Power Systems Ltd.<\/span><\/a>1<\/sup><\/a><\/span><\/span><\/span><\/p>\n

19<\/span>. While dealing with a case under Section 79(a<\/span>) and (b<\/span>) of the unamended section [Clause (b<\/span>) was deleted with effect from 1 April 1989] and while relating to Clause (a<\/span>) of Section 79 of the Act, the Supreme Court in CIT<\/span> v. Italindia Cotton Co. (P) Ltd.<\/span><\/span><\/a><\/span>2<\/sup><\/a><\/span>, held that the section would be applicable only when there is change in shareholding in the previous year which may result in change of control of the Company and that every such change of shareholding need not fall within the prohibition against the carry forward and set off of business losses. In the present case, though there may have been change in the shareholding in Assessment Year 2002-2003, yet, there was no change of control of the Company, as the control remained with the ABL as the voting power of ABL, along with its subsidiary company APIL, remained at 51 per cent. The Supreme Court further observed that the object of enacting Section 79 appears to be to discourage persons claiming a reduction of their tax liability on the profits earned in the companies which had sustained losses in earlier years. In the present case, the control over the Company, with 51 per cent voting power, remained with ABL and, as such, in our view, the provisions of Section 79 of the Act would not be attracted.<\/span><\/p>\n

20.<\/span> Accordingly, we answer the first question in favour of the assessee and against the Revenue, and confirm the finding of the Tribunal in this regard.<\/p>\n

(ii<\/span>) Hiranandani Healthcare (P) Ltd.<\/span> v. CIT<\/span><\/a><\/span>3<\/sup><\/a><\/span><\/p>\n

8.<\/span> We heard the rival contentions and perused the record. There is no dispute with regard to the fact the assessee company is held by two shareholders, viz. FHL and FHHPL, both in the years in which losses were incurred and in the years in which the said accumulated losses are sought to be set off. A careful perusal of Section 79 would show that the said provision bars setting off brought forward losses if the shares of the company carrying not less than 51 per cent of the voting power were not the beneficially held by the very same persons in the years in which the losses were incurred and the years in which the said loss was sought to be set off. The contention of the assessee is that the use of expression “persons” in Section 79 of the Act would signify that the “group of shareholders” in contrast to a single person. If the 51 per cent of voting power is held by very same group of persons, then the provisions of Section 79 would not be applicable, meaning thereby, the inter se<\/span> change between the same group will not be hit by Section 79 of the Act.<\/p>\n

9<\/span>. In the instant case, we noticed that there are only two shareholders, viz. FHL and FHHPL. Both the abovesaid shareholders, as a group, has beneficially held 51 per cent of the voting power in both the years, i.e.<\/span>, the year in which loss was incurred and the year in which the loss was sought to be set off, meaning thereby, there is no change in the shareholding pattern of the group. We further noticed that the FHHPL is holding company of FHL. Hence, the increase in shareholding of FHL in the assessee company, in any case, would not result in the change in the voting power of the shareholders. Accordingly, we find merit in the contentions of the learned Authorised Representative that the provisions of Section 79 will not be applicable in the facts of the present case. Hence, we are not able to agree with the view expressed by the tax authorities that the change in individual shareholding of the shareholders would also attract provision of Section 79 of the Act. Accordingly, we set aside the order passed by the learned CIT(A) on this issue and direct the Assessing Officer to allow set off brought forward losses both in Assessment Years 2012-2013 and 2013-2014.<\/p>\n

2. Tier 2: Unabsorbed depreciation and development rebates not covered under the scope of Section 79<\/span><\/p>\n

(a<\/span>) Exclusions from Section 79: Unabsorbed depreciation and other allowances: Assessing Officers mistakenly clubbing unabsorbed depreciation and unabsorbed development rebates with business losses to deny their carry forward under the limits of Section 79. These cases confirm that restrictions under Section 79 strictly apply to business losses and do not extend to unabsorbed depreciation or development rebate.<\/p>\n

(i<\/span>) Sunshine Granites (P) Ltd.<\/span> v. CIT<\/span><\/a>4<\/sup><\/a><\/span><\/p>\n

10.<\/span> We have gone through the record in the light of the submissions made on either side. It could be seen from the impugned order that the assessee had taken the plea that Section 79 of the Act has no application to the facts of this case and it had taken a specific plea by way of additional grounds that Section 79 of the Act refers to business loss only and it has nothing to do with the giving the credit for set off of carry forward unabsorbed depreciation loss. Whether or not Section 79 of the Act applies to the carry forward of unabsorbed depreciation loss is only a question of law, and would have been decided by the learned CIT(A) even in the absence of the assessee, because the decision of the higher forum equally binds the learned CIT(A) as it binds all the authorities before that forum.<\/p>\n

11<\/span>. The Supreme Court is clear on this aspect and in the case of Shri Subhlaxmi Mills Ltd.<\/span><\/a>5<\/sup><\/a><\/span> expressly approved the view taken by the Gujarat High Court that when Section 79 of the Act speaks of loss, it does not include unabsorbed depreciation or unabsorbed development rebate. Since it is neither a pure nor mixed question of fact, it does not admit of any further factual findings of the learned CIT(A), but involves only interpretation of the provision by the learned CIT(A). When the Supreme Court speaks on the non-applicability of Section 79 of the Act to the unabsorbed depreciation loss, any opinion of learned CIT(A) on this aspect is immaterial, and suffice it to cause verification whether the carry forward losses of Assessment Year 2012-13 sought to be set off against the future losses by the assessee including Assessment Year 2013-2014, include any unabsorbed depreciation. If it is so, it is eligible for set off against the profits of the future years.<\/span><\/p>\n

12<\/span>. With this view of the matter, we direct the learned Assessing Officer to verify whether the carry forward losses of Assessment Year 2012-13 sought to be set off against the future losses by the assessee including Assessment Year 2013-2014, include any unabsorbed depreciation, and if it is so allowed, it to be set off against the profits of the future years. Subject to this observation, appeal is allowed.<\/p>\n

(ii<\/span>) CIT<\/span> v. Credila Financial Services (P) Ltd.<\/span><\/a>6<\/sup><\/a><\/span><\/p>\n

7. 7<\/span>.14<\/span> First of all, we shall discuss about the carried forward of unabsorbed depreciation of the earlier years. Perusal of provisions of Section 79 of the Act read in conjunction with Section 72-A of the 1961 Act which incidentally falls in the same Chapter VI which deals with Chapter ‘Aggregation of Income and set off or carry forward of loss’ will reveal that both the aforestated sections deals with provisions relating to carry forward and set off of accumulated loss and unabsorbed depreciation in different circumstances, the perusal of these two sections reveal that wherever statute wanted it has used unabsorbed depreciation and accumulated losses separately which is evident from provisions of Section 72-A, while in Section 79 the lawmakers have consciously restricted to disallowance of losses under certain circumstances while there is no mention of unabsorbed depreciation in Section 79. The provisions of Section 72-A deals with the provisions relating to carry forward and set off of accumulated loss and unabsorbed depreciation allowance in amalgamation or demerger etc. while Section 79 of the 1961 Act deals with the provisions for carry forward and set off of losses in case of certain companies in which public are not substantially interested and there has been a change in shareholding carrying not less than fifty-one per cent of the shareholding. Taxing statute are to be construed strictly and when the language used in taxing statute is clear, plain, simple and unambiguous, it is impermissible to insert or delete words into taxing statute which are not mentioned therein by the legislature. The taxing statute are to be strictly construed as per the language used by legislatures if the words used are simple clear, plain and unambiguous provided the results produced by their use are not absurd, albeit the result produced may be harsh. No words are to be ordinarily added or deleted from the statute as there are no surplusages in the words used by legislature in enacting statute and each word so used by legislature has to be given ordinarily full effect. Perusal of provisions of Section 79 clearly reveals that it did not speak about carry forward and set off of unabsorbed depreciation and in our considered view the bar created by provisions of Section 79 will not be applicable so far as carry forward and set off of unabsorbed depreciation is concerned. The Supreme Court in CIT<\/span> v.<\/span> Shri Subhulaxmi Mills Ltd.<\/span>, (2001) 10 SCC 658 : (2001) 249 ITR 795<\/span><\/span> has affirmed the decisions of Gujarat High Court in the case of Shri Subhulaxmi Mills Ltd. by holding that Section 79 has no applicability so far as carry forward and set off unabsorbed depreciation is concerned. The relevant portion of decision of Supreme Court in the case of CIT<\/span> v. Shri Subhulaxmi Mills Ltd.<\/span> is reproduced hereunder:<\/span><\/p>\n

“3<\/span>. So far as question No. 2 is concerned, the question is whether in applying Section 79 of the Act, only the business loss should be taken into account and not the unabsorbed depreciation or unabsorbed development rebate. The High Court has answered the question saying that when Section 79 speaks of loss, it does not include unabsorbed depreciation or unabsorbed development rebate. We agree with the High Court.”<\/p>\n

Thus, keeping in view aforesaid decision of Supreme Court, we hold that the assessee will be entitled for carry forward and set off<\/span> of unabsorbed depreciation for Assessment Years 2007-2008 to 2012-2013 and we hold that Section 79 of the 1961 Act has no applicability so far as carry forward and set off of unabsorbed depreciation is concerned. The assessee succeeds so far as this ground raised by the assessee being ground No. 2 in the cross-objection filed with the Tribunal. We order accordingly.<\/p>\n

3. Tier 3: The intersecting law defence (Corporate insolvency)<\/span><\/p>\n

(a<\/span>) The IBC Override: Examining the intersection of the Income-tax Act, 1961<\/span><\/span> and the Insolvency and Bankruptcy Code (IBC\/CIRP). This will detail how the Revenue is barred from denying the carry forward of losses to a successful resolution applicant if they failed to file formal objections during the NCLT approval process.<\/span><\/p>\n

Amns Gandhidham Ltd.<\/span> v. CIT<\/span><\/span>7<\/sup><\/a><\/span><\/span><\/p>\n

12. This issue has also come up for consideration before this Court in the case of Swan Defence and Heavy Industries Ltd.<\/span> v<\/span>. CIT<\/span>8<\/sup><\/a><\/span><\/span>. In that case, following the ratio laid down by the Supreme Court in Ghanashyam Mishra & Sons (P) Ltd.9<\/sup><\/a><\/span> (supra) similar actions of the Income Tax Department were set aside.<\/span><\/p>\n

13.<\/span> Similarly, in Alok Industries Ltd.<\/span> v. CIT<\/span><\/a>10<\/sup><\/a><\/span>, Uttam Galva Metallics Ltd.<\/span> v. CIT<\/span><\/a>11<\/sup><\/a><\/span><\/span><\/span> and passed by this Court in Ornate Spaces (P) Ltd.<\/span> v. CIT<\/span><\/span>12<\/sup><\/a><\/span><\/span><\/span>, following the ratio of the judgment of the Supreme Court in the case of Ghanashyam Mishra & Sons (P) Ltd. (supra), this Court has quashed the proceedings taken by the Income Tax Authorities for periods prior to the implementation date in view of the approval of the resolution plan by the NCLT.<\/span><\/p>\n

14. As regards to the Revenue’s contention that allowability of losses can be examined by the Respondents, we find that this would not be permissible in the facts of the present case because notice to the Principal Commissioner under Section 79(2)(c) of the IT Act was served on the Principal Commissioner on 28 June 2022 and the Principal Commissioner did not make any submissions at the time when the resolution plan was approved by the NCLT or any time prior thereto. Once this is the case, denial of carry forward of losses cannot be denied to the petitioner. We say this also because we find merits in the petitioner’s contention that availability of such losses would be one of the factors that would have been taken into account by the resolution applicant when submitting its proposal to take over the corporate debtor (namely, the petitioner).<\/p>\n

15. In view of the above, the impugned proceedings for Assessment Years 2022-2023 and 2023-2024 are quashed and set aside. However, there shall be no order as to costs.<\/p>\n

4. Tier 4: The procedural and jurisdictional defence<\/span><\/p>\n

(a<\/span>) Challenging the AO’s Timing: Establishing that the jurisdiction to adjudicate the validity of a carry-forward claim lies exclusively with the Assessing Officer assessing the year the set off<\/span> is claimed, invalidating any premature, binding denials recorded in the year the loss was merely generated. These decisions clarify that the authority to adjudicate the set-off of a brought forward loss lies exclusively with the Assessing Officer assessing the year in which the set off is claimed, not the year the loss was generated.<\/p>\n

(i<\/span>) PCIT v. Burda Druck India (P) Ltd.<\/a><\/span><\/span>13<\/sup><\/a><\/span><\/p>\n

16.2<\/span> A textual reading of Section 79 makes it evident that it does not empower an AO, who exercises jurisdiction qua a particular AY, to place limitations on the adjudicatory powers of the AO who would be called upon to deal with the matter in subsequent years.<\/p>\n

20.<\/span> There is, in our opinion, no practical efficacy in the assessee carrying forward business losses, unabsorbed depreciation, and capital losses unless there is a possibility of setting off those losses in the future, albeit subject to the provisions of the Act. These are the aspects, in our opinion, that the concerned AO would examine in the relevant AY in which such set off is claimed.<\/p>\n

20.1<\/span> Therefore, the mere fact that the Tribunal has expunged the impugned observations, in our view, cannot impact the stand of the appellant\/Revenue.<\/p>\n

20.2<\/span> Thus, for the aforesaid reasons, in our opinion, no interference is called for with the impugned order.<\/p>\n

(ii<\/span>) CIT v. Instant Traders (P) Ltd.<\/a><\/span><\/span>14<\/sup><\/a><\/span><\/span><\/span><\/p>\n

5.<\/span> After having carefully considered the rival submissions, we find that the limited plea of the assessee before us is to the effect that the dispute regarding the denial of the carry forward of loss on the basis of prohibition contained in Section 79 of the Act be considered by the assessing officer in accordance with law in the subsequent year where the assessee claims actual set off. An identical situation has been considered by our coordinate Bench in the case of Khajrana Ganesh Properties (P) Ltd.<\/span> v. CIT<\/span><\/a><\/span>,15<\/sup><\/a><\/span> wherein one of us is part of the Bench. The Tribunal, by relying the judgment of Supreme Court in the case of CIT<\/span> v. Manmohan Das (Deceased)<\/span>, 1965 SCC OnLine SC 210, noted that whether or not loss in any year can be carried forward and set off in the subsequent year is liable to be determined by the assessing officer who deals with the assessment of such subsequent year. In fact, the Supreme Court specifically noted that the decision recorded by the assessing officer, who computes the loss in preceding year that loss cannot be set off in the subsequent year is not binding on the assessee in the subsequent actual year of set off. Considered in this light, the coordinate Bench in the case of Khajrana<\/span> Ganesh Properties (P) Ltd.<\/span>, 2017 SCC OnLine ITAT 13289 came to conclude that it is only the assessing officer dealing with the assessment of the assessment year where the assessee has claimed set off of the loss is competent and not the assessing officer of the earlier year. The relevant decision of the coordinate Bench is as under:<\/span><\/p>\n

“We have carefully considered the rival submissions and find that the issue before us can be disposed off in the light of the point of law laid down by the Supreme Court in the case of Manmohan Das<\/span> (Deceased). As per the Supreme Court, whether the loss in any year may be carried forward to the following year and set off against the income of the subsequent year is liable to be determined by the assessing officer who deals with the assessment of such subsequent year. The Supreme Court further noted that a decision recorded by the assessing officer who computes the loss in a previous year that the loss cannot be set-off against the income of the subsequent year is not binding on the assessee in the subsequent actual year of set-off. Considered in this light, in our view, the assessing officer in the instant year had no jurisdiction to give a finding that the loss of Rs 7,96,21,402 cannot be carried forward and set off against the income of the subsequent year. Therefore, such observations\/directions of the assessing officer, in our view, are bereft of jurisdiction and are accordingly directed to be removed. So however, our aforesaid decision should not be understood as any reflection on the merit or otherwise of invoking of Section 79 of the Act prohibiting carry forward and set off of loss in certain situations. The application of Section 79 of the Act shall be open to be considered by the assessing officer in the subsequent year while evaluating the claim of the assessee for set off of the impugned business loss. As a consequence of our aforesaid discussion, we set aside the order of CIT(A) and direct the assessing officer to remove the directions relating to denial of carry forward and set off of loss of Rs 7,96,21,402.<\/p>\n

Thus, on this aspect, assessee succeeds for statistical purposes.”<\/p>\n

6<\/span>. Considering in the aforesaid light, in our view, so far as the instant assessment year is concerned, the assessing officer is not competent to give a finding that the loss cannot be carry forward and set off against the income of the subsequent year. Accordingly, the matter is remanded back to the file of the assessing officer to remove the direction relating to denial of carry forward and set off of loss. However, our direction should not be interpreted to be any reflection on the merits of invoking Section 79 of the Act, which prohibits carry forward and set off of loss in specified situations. The same shall be open to be considered by the assessing officer in the subsequent year of actual set off while evaluating the claim of the assessee for set off of the impugned business loss.<\/p>\n

7<\/span>. As a consequence of our aforesaid discussion, we set aside the order of the CIT(A) and direct the assessing officer to expunge the directions so far as it relates to denial of carry forward and set off of loss. Thus, on this aspect the assessee succeeds for statistical purposes only.<\/p>\n

Opinion<\/h2>\n

The jurisprudence surrounding Section 79 underscores a fundamental tenet of tax litigation: the Revenue’s jurisdiction and interpretation are not absolute. The defence against a Section 79 disallowance requires a composite strategy that transcends the Income-tax Act, 1961<\/span><\/span> itself. Litigators must meticulously document the unbroken chain of “beneficial voting power” during internal restructurings, explicitly challenge the erroneous clubbing of unabsorbed depreciation, and invoke the clean-slate doctrine under the IBC where applicable.<\/span><\/p>\n

Protecting value in corporate restructuring<\/h2>\n

For companies undergoing mergers, acquisitions, or insolvency resolutions, accumulated losses are a vital financial asset. The mechanical application of Section 79 by tax authorities can severely erode the value of a restructured entity or deter a prospective resolution Applicant. This four-tier defence strategy provides a vital roadmap for protecting that value. Whether it is proving that a holding-subsidiary reshuffle did not alter the ultimate controlling group, or utilising the legal shield provided by the NCLT approval process to bar retrospective tax claims, the law provides ample room to protect the taxpayer. By embedding these substantive, intersecting, and procedural defences into the early stages of transaction planning, companies can confidently carry forward their losses and secure their financial footing for the future.<\/p>\n<\/div>\n\n

*Fellow Chartered Accountant (FCA). Author can be reached at: mksatya1993@gmail.com.<\/span><\/strong><\/p>\n

**Law Student. Author can be reached at: ssatya7080@gmail.com.<\/span><\/strong><\/p>\n

1.<\/a> 2015 SCC OnLine Kar 8721<\/a> : (2015) 379 ITR 375<\/citref>, 384.<\/p>\n

2.<\/a> (1988) 4 SCC 221<\/a> : (1988) 174 ITR 60.<\/p>\n

3.<\/a> 2023 SCC OnLine ITAT 1421<\/a> : (2023) 225 TTJ 397, 400-401.<\/p>\n

4.<\/a> 2024 SCC OnLine ITAT 5997<\/a>.<\/p>\n

5.<\/a> CIT<\/span> v. Shri Subhlaxmi Mills Ltd.<\/span>, 1976 SCC OnLine Guj 70<\/a> : (1983) 143 ITR 863.<\/p>\n

6.<\/a> 2018 SCC OnLine ITAT 8021<\/a> : (2018) 64 ITR(T) 324.<\/p>\n

7.<\/a> 2025 SCC OnLine Bom 5951.<\/p>\n

8.<\/a> 2025 SCC OnLine Bom 5862.<\/p>\n

9.<\/a> (2021) 9 SCC 657<\/a>.<\/p>\n

10.<\/a> (2024) 471 ITR 536<\/a>.<\/p>\n

11.<\/a> (2024) 471 ITR 592<\/a> : (2024) 246 Comp Cas 678<\/a>.<\/p>\n

12.<\/a> 2025 SCC OnLine Bom 6509.<\/p>\n

13.<\/a> (2025) 483 ITR 469<\/a>.<\/p>\n

14.<\/a> 2018 SCC OnLine ITAT 13360<\/a>.<\/p>\n

15.<\/a> 2017 SCC OnLine ITAT 13289<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":"

by Mahendra K. 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