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TMI Blog2022 (7) TMI 431X X X X Extracts X X X X X X X X Extracts X X X X ..... ain conditions. Here in this case the previous year is 2013-14 and the relevant 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 not mean that the losses incurred during the assessment year 2014-15 (in the financial year 2013-14) are not to be allowed to be carried forward. With this view of the matter, we find that the observations of the authorities below that the current year losses are not to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer, assessee preferred appeal and pleaded 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 complete during the previous year relevant to the assessment year 2014- 15 and, therefore, the stand taken by the learned Assessing Officer in making disallowance of the losses for the assessment year 2014-15 was correct. On this premise, Ld. CIT(A) dismissed the appeal of the assessee. 4. Aggrieved by the or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ous year shall be carried forward and set off against the income of the previous year, but subject to certain conditions. Here in this case the previous year is 2013-14 and the relevant 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 not mean that the losses incurred during the assessment year 2014-15 (in the financial year 2013-14) are not to be allowed to be carried forward. With this view of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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