No Set-off of Loss from Undisclosed Income
Introduction
Section 79A prohibits the set-off of any loss (brought forward or otherwise) or unabsorbed depreciation against undisclosed income discovered through search, requisition, or survey.
Prohibition on Set-off of Losses
Losses cannot be set-off against undisclosed income found during:
- Asearchunder Section 132.
- Arequisitionunder Section 132A.
- Asurveyunder Section 133A (excluding Section 133A(2A)).
Meaning of Undisclosed Income
- Income Represented by any Asset or Book Entry or transaction:
o Includes money, bullion, jewellery, or other valuables, or book entries/transactions not recorded in regular books or disclosed to the PCCIT/CCIT/PCIT/CIT before the search, survey or requisition date.
- Income Represented by False Expenditure:
o Includes entries for expenses found false during search, survey or requisition that would not have been detected otherwise.