Yum India cannot offset past business losses due to shareholding change u/s 79 of Income Tax Act.

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....Carry forward accumulated business losses - change in shareholding - The question of 'piercing the veil' at the instance of Yum India does not arise. - in terms of Section 79 of the Act, Yum India cannot be permitted to set off the carry forward accumulated business losses of the earlier years. - HC....