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Income-tax Act 2025 Chapter VII — Set Off and Carry Forward of Losses (Sections 108–121)

Complete section-by-section mapping of Chapter VII (sections 108–121) of the Income-tax Act, 2025 to the Income-tax Act, 1961, with what changed and why.

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Income Tax
Published
September 5, 2026
Last updated
Oct 7, 2026
Reading time
4 min
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Last updated: October 2026Applies to: FY 2026-27 (AY 2027-28)Verified against: Government sources

What Chapter VII covers

Chapter VII covers set off and carry forward of losses — within a head, across heads, and forward into later years, including what happens on amalgamation, demerger and change in shareholding.

Chapter VII contains 14 sections (sections 108 to 121). Between them they carry forward the substance of 15 sections of the Income-tax Act, 1961.

When this applies

The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and takes effect from 1 April 2026. The Income-tax Act, 1961 continues to govern every tax year up to 31 March 2026, and all assessments, appeals, penalties and prosecutions relating to those years are completed under the old Act by virtue of the repeal and savings provision in section 536. The mapping on this page is drawn from the section-wise concordance published with the Act, including the corrigenda notified in the Gazette on 3 September 2025.

What changed in Chapter VII

  • Section 119 merges sections 78 and 79, so the closely held company shareholding test and the firm succession restriction are read together.
  • Capital loss carry forward moves to section 111 (old section 74) and business loss to section 112 (old section 72).
  • Section 121 carries section 80 — the rule that a loss must be returned in time to be carried forward. This remains the single most common reason carried-forward losses are lost.
  • Section 120 carries section 79A: no set off of losses against undisclosed income found in search, requisition or survey.

Chapter VII: complete section mapping (2025 → 1961)

Every section of Chapter VII is listed below with the section or sections of the Income-tax Act, 1961 that it corresponds to. Where a section is marked as read with a Schedule, the operative detail sits in that Schedule rather than in the section itself.

New section (2025)ProvisionCorresponding 1961 section(s)
108Set off of losses under same head of income70
109Set off of losses under any other head of income71
110Carry forward and set off of loss from house property71B
111Carry forward and set off of loss from Capital gains74
112Carry forward and set off of business loss72
113Set off and carry forward of losses computed in respect of speculation business73
114Set off and carry forward of losses computed in respect of specified business73A
115Set off and carry forward of losses from specified activity74A
116Treatment of accumulated losses and unabsorbed depreciation in amalgamation or demerger, etc72A
117Treatment of accumulated losses and unabsorbed depreciation in scheme of amalgamation in certain cases72AA
118Carry forward and set off of losses and unabsorbed depreciation in business reorganisation of co- operative banks72AB
119Carry forward and set off of losses not permissible in certain cases78, 79
120No set off of losses against undisclosed income consequent to search, requisition and survey79A
121Submission of return for losses80

How to use this mapping

  • Working on a year up to 2025-26? Use the 1961 section in the right-hand column. The old Act governs those years under section 536.
  • Working on tax year 2026-27 onwards? Use the new section number in the left-hand column, and read the section text rather than assuming the old provision was copied verbatim.
  • Drafting a reply or an appeal? Cite the section that applies to the year in dispute, not the section in force when you are writing.
  • Updating templates and software? Sections that merged — shown where one new section maps to several old ones — need the most attention, because a single new provision now carries what were separate conditions.
Please note

This page is a structural mapping guide, not tax advice. A corresponding section is not always an identical section — several provisions were merged, split or re-worded when they were carried over. Always read the actual text of the new section before relying on it, and check for later amendments, rules and CBDT notifications.

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Which sections make up Chapter VII of the Income-tax Act, 2025?

Chapter VII runs from section 108 to section 121 — 14 sections in all — and is headed “Set Off and Carry Forward of Losses”.

How many 1961 sections does Chapter VII replace?

The sections in this chapter carry forward the substance of 15 sections of the Income-tax Act, 1961. Some new sections merge several old ones, which is why the counts differ.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Short, direct answers to the 5 questions readers ask most on this topic.

Chapter VII runs from section 108 to section 121 — 14 sections in all — and is headed “Set Off and Carry Forward of Losses”.

The sections in this chapter carry forward the substance of 15 sections of the Income-tax Act, 1961. Some new sections merge several old ones, which is why the counts differ.

From 1 April 2026, that is tax year 2026-27 onwards. Every year up to 31 March 2026 continues under the Income-tax Act, 1961 because of the repeal and savings provision in section 536.

Section 121 corresponds to section 80 of the 1961 Act, which required the loss to be determined in a return filed within the section 139(1) time limit. Read section 121 with section 263 for the current wording.

Section 116, carrying forward section 72A. Section 117 covers amalgamation schemes under section 72AA and section 118 covers business reorganisation of co-operative banks under section 72AB.