The Statutory Brief

IT Act 1961 → 2025 / Sections 72A–79A

Losses

Sections 72A–79A → Sections 114–120

Losses on amalgamation/demerger (72A), banks (72AA), specified business (73A), change in shareholding (79), no set-off against search income (79A)

Sections 72A–79A of the old Income-tax Act, 1961 · new sections 114–120 under the Income-tax Act, 2025

New reference Sections 114 to 120

Income-tax Act, 1961Sections 72A–79A

  • 72A: carry forward of losses on amalgamation or demerger
  • 73A: losses of specified (35AD) businesses
  • 78, 79: change in constitution of firm; change in shareholding of closely held companies (51% test)
  • 79A: no set-off against undisclosed income found in search or survey

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Sections 114 to 120

  • 116, 117, 118: amalgamation, bank amalgamation, co-operative bank reorganisation
  • 114: specified business losses; 115: losses from specified activities (old 74A)
  • 119: one section replacing 78 and 79
  • 120: no set-off against undisclosed income

Applies from tax year 2026-27 (from 1 April 2026).

Section-by-section mapping (8 sections)

1961 ActSubject2025 Act
72ALosses on amalgamation or demerger116
72AALosses on amalgamation of banking companies117
72ABLosses on business reorganisation of co-operative banks118
73ACarry forward and set off of losses by specified business114
74ALosses from certain specified sources falling under the head "Income from other sources"115
78Carry forward and set off of losses in case of change in constitution of firm or on succession119
79Carry forward and set off of losses in case of certain companies119
79ANo set off of losses consequent to search, requisition and survey120

Source: CBDT mapping of sections, Income-tax Act 1961 to Income-tax Act 2025.

What changed

Renumbered; sections 78 and 79 are merged into section 119.

Practice notes

  • General set-off and carry forward (70–74) has its own pages.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

What is section 72A called in the new Income-tax Act, 2025?

Section 72A of the Income-tax Act, 1961 (Losses on amalgamation or demerger) corresponds to section 116 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 72AA called in the new Income-tax Act, 2025?

Section 72AA of the Income-tax Act, 1961 (Losses on amalgamation of banking companies) corresponds to section 117 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 72AB called in the new Income-tax Act, 2025?

Section 72AB of the Income-tax Act, 1961 (Losses on business reorganisation of co-operative banks) corresponds to section 118 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 73A called in the new Income-tax Act, 2025?

Section 73A of the Income-tax Act, 1961 (Carry forward and set off of losses by specified business) corresponds to section 114 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 74A called in the new Income-tax Act, 2025?

Section 74A of the Income-tax Act, 1961 (Losses from certain specified sources falling under the head "Income from other sources") corresponds to section 115 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What is section 78 called in the new Income-tax Act, 2025?

Section 78 of the Income-tax Act, 1961 (Carry forward and set off of losses in case of change in constitution of firm or on succession) corresponds to section 119 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What changed in Sections 72A–79A under the new Income Tax Act?

Renumbered; sections 78 and 79 are merged into section 119.

Related sections

70 / 71→108Set-off of losses in the same year: within a head and across heads71B→110Carry forward of house property loss72→112Carry forward and set-off of business losses74→111Carry forward of capital losses