Section 79 gets attracted in case of change in more than 51% of shareholding despite being the same within the group

Just Lifestyle (P) Ltd. Vs DCIT (ITAT Mumbai) The provision of section 79 of the Act, clearly specify that no loss incurred by a closely held company in any year prior to the previous year in which a change in its shareholding took place, is allowed to be carried forward and set off against its income, unless the condition mentioned in that section are satisfied. The first condition is that on the last day of the previous year, there is no change in the beneficial holding of the shares of the company, carrying not less than 51% of the voting power. The second condition is that the satisfaction...