ITAT allows carry forward of losses in case of shares held by ultimate holding company

Bechtel France SAS Vs DCIT (ITAT Mumbai) Facts: The taxpayer is a company incorporated in France and engaged in the business of procurement and construction. It had set up a project office at Mumbai with site offices at other locations in India to build certain refinery and certain complex. The Commissioner of Income-tax observed that there was a change in the immediate shareholding pattern of the taxpayer during the year under consideration (viz. FY 2013-14, corresponding to AY 2014-15), from one group company to another group company. Accordingly, the CIT invoked its revisionary powers unde...