Case Law Analysis
|Supreme Court of India
No Successor Entitlement to Pre-Amalgamation Losses Under Kerala Agricultural Income Tax Act : SC | Section 54 Bars Set-Off Without Explicit Statutory Provision
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.