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ITA 1961 → DTC 2025Set off and Carry Forward

Section 72A Section 93

Carry forward and set off of accumulated loss and unabsorbed depreciation in amalgamation or demerger

RetainedHigh - The most critical tax provision for corporate M&A (Mergers and Acquisitions).

Quick Answer

Section 72A of the Income Tax Act, 1961 (Carry forward and set off of accumulated loss and unabsorbed depreciation in amalgamation or demerger) corresponds to Section 93 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.

Old Law (ITA 1961)Ch: VI

Sec 72A

Provision Summary

Allows the amalgamated/resulting company to carry forward business losses and unabsorbed depreciation of the amalgamating/demerged company.

New Law (DTC 2025)Ch: X

Sec 93

Provision Summary

Retained. Rules simplified specifically for public sector bank amalgamations and strategic disinvestment of PSUs.

Key Changes & Highlights

  • Conditions regarding maintaining 3/4th book value of assets strictly monitored via MCA (Ministry of Corporate Affairs) API integration.

Frequently Asked Questions

What does Section 72A of the Income Tax Act 1961 deal with?

Section 72A (Carry forward and set off of accumulated loss and unabsorbed depreciation in amalgamation or demerger) Allows the amalgamated/resulting company to carry forward business losses and unabsorbed depreciation of the amalgamating/demerged company.

What is the new section number for Section 72A under the Direct Tax Code 2025?

Section 72A of the ITA 1961 maps to Section 93 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.

What is the status of Section 72A under the new tax code?

Section 72A is marked as "Retained" with status "Modified". Impact: High - The most critical tax provision for corporate M&A (Mergers and Acquisitions).

What are the key changes to Section 72A under DTC 2025?

Conditions regarding maintaining 3/4th book value of assets strictly monitored via MCA (Ministry of Corporate Affairs) API integration.

Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.

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