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Case lawIncome-tax Act 2025Chapter VII › Section 121
Chapter VIIwas s.80

Section 121 of the Income-tax Act, 2025

Section 121 — Submission of return for losses. Successor to s.80 of the 1961 Act.

Where this section sits

Section 121 is in Chapter VII — Set Off or Carry Forward and Set Off of Losses, which runs from section 108 to section 121.

← Section 120  ·  Section 122 →

What this section does

The section overrides the rest of the Chapter to impose a single condition on carrying losses forward. No loss that has not been determined in pursuance of a return filed under section 263(1) may be carried forward and set off under section 111(1), 112(1), 113(2), 114(2) or 115(2).

Why it is there

A loss claimed for the first time years later cannot be checked against the year in which it is said to have arisen. The section makes the return under section 263(1) the only gateway for a loss into the carry-forward machinery, so that the figure carried forward is one determined on a return the Department has had before it.

Who it applies to

What this means in practice

The condition is about determination, not merely claiming: the loss must have been determined in pursuance of a return filed under section 263(1). If no such return was filed for the year the loss arose, the loss is unavailable however well documented in the books. The bar is confined to the five provisions named, so a carry-forward running otherwise is not addressed here. The practical consequence is that the return for a loss year has to be filed, even where there is no tax to pay and nothing else compels a filing.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

A firm makes a business loss of Rs. 40 lakh in a tax year and, having no tax to pay, files no return for that year. In the next year it earns a profit of Rs. 60 lakh and seeks to set off the brought forward loss. Section 121 stops it: the Rs. 40 lakh was never determined in pursuance of a return filed under section 263(1), so it cannot be carried forward and set off under section 111(1), and the whole Rs. 60 lakh is taxable.

Where you meet this section

In the loss carried forward schedule of the return, and in an assessment order or intimation disallowing a brought forward loss because no return was filed for the year in which it arose.

The words themselves

no loss which has not been determined in pursuance of a return filed under section 263(1), shall be carried forward and set off
Section 121, Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Circulars of the Board on this section

A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.

See every circular and notification on this section, or the circulars index.

Notifications that reach this section

A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance.

See every circular and notification on this section, or the notifications index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 121. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

Read with

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.