#agricultural income tax

The Supreme Court ruled that an amalgamated company cannot claim set-off of pre-amalgamation losses under the Kerala Agricultural Income Tax Act, 1991, as Section 54 does not expressly permit such transfer. The judgment underscores that contractual clauses cannot override statutory limitations, impacting corporate restructuring and tax planning strategies.

The Gauhati High Court reaffirmed that a tax amendment effective from April 1 governs the assessment of income earned in the preceding financial year, aligning with the Supreme Court's precedent in Karimtharuvi Tea Estate Ltd. vs. State of Kerala. This ruling underscores that tax liability is determined by the law in force on the first day of the assessment year, not the financial year of income accrual, impacting agricultural income tax assessments under the Assam Agricultural Income Tax Act.