Relevant Date for MAT Loss Set-Off Is Prior Year-End, Not Assessment Year-End

Bay Forge Pvt. Ltd. Vs ACIT (ITAT Chennai)

The appeal was decided by the Income Tax Appellate Tribunal, Chennai Bench and related to Assessment Year (AY) 2005–06. The assessee challenged the order of the Commissioner of Income Tax (Appeals), which had upheld the reassessment completed under section 143(3) read with section 147 of the Income-tax Act, 1961.

The assessee, a private limited company, filed its return of income for AY 2005–06 declaring nil income after adjusting carried forward business losses. Its tax liability under the Minimum Alternate Tax

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