VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — section 79A: no set-off against undisclosed income found in a search, requisition or survey, from AY 2022-23
CBDT Circulars & InstructionsCuts both wayss.79As.115BBEs.115BBE(2)s.68s.69s.69As.69Bs.69Cs.69Ds.32(2)s.132s.132As.133As.70s.71s.72

Statutory position — section 79A: no set-off against undisclosed income found in a search, requisition or survey, from AY 2022-23

A search threw up unaccounted stock and cash and the Assessing Officer has added it. I have a large brought-forward loss and unabsorbed depreciation sitting there. Can I set them off against the addition?

A search threw up unaccounted stock and cash and the Assessing Officer has added it. I have a large brought-forward loss and unabsorbed depreciation sitting there. Can I set them off against the addition?

For AY 2022-23 and every later year, no. Section 79A, inserted by the Finance Act 2022 (Act No. 6 of 2022) with effect from 1 April 2022, says that where, consequent to a search under s.132, a requisition under s.132A or a survey under s.133A other than s.133A(2A), the total income of any previous year includes undisclosed income, no set-off of any loss — brought forward or of the current year — and no set-off of unabsorbed depreciation under s.32(2) shall be allowed against that undisclosed income under any provision of the Act.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2022-04-01, reported as Inserted by the Finance Act, 2022 (Act No. 6 of 2022), with effect from 1 April 2022, that is Assessment Year 2022-23. It bears on section 79A, section 115BBE, section 115BBE(2), section 68, section 69, section 69A, section 69B, section 69C, section 69D, section 32(2), section 132, section 132A, section 133A, section 70, section 71, section 72 of the Income Tax Act 1961, in Search, Survey & Block Assessment, Cash Credits & Unexplained Money and How Tax Law Is Read matters.

Still good law. This is the amending law itself, not a decision about it. The text was verified on 8 September 2026 on five departmental pages for the section, the most recent stamped Year 2025, all carrying the correct heading and the single insertion footnote. No decided case APPLYING s.79A to deny a set-off was located. An Indian Kanoon phrase search on the section's own operative words, 'no set off, against such undisclosed income, of any loss', returned exactly two documents — the bare-Act page for s.79A and the Madras High Court judgment in M/s Sivasakthi Threads v. DCIT (23 January 2026), which mentions the section only to hold it prospective. Searches on the section heading and on the string 'section 79A of the Act' returned nil, but the Indian Kanoon phrase index is not a dependable substring match and alphanumeric section numbers are known to break it, so the absence of authority is NOT established. Later treatment of the section by any court has not been checked beyond those searches.

Why it matters

This is the provision that now fixes what a s.68 to s.69D addition actually costs, and it is wider in three ways than the s.115BBE(2) bar that practitioners already know. First, s.115BBE(2) switches off deductions and set-off only in computing income 'referred to in clause (a) and clause (b) of sub-section (1)' — that is, income referred to in ss.68, 69, 69A, 69B, 69C and 69D. Section 79A is not tied to those sections at all: it bites on 'undisclosed income' as defined in its own Explanation, which turns on whether the item was recorded in the books before the date of search, requisition or survey, or disclosed to the Principal Chief Commissioner, Chief Commissioner, Principal Commissioner or Commissioner before that date — plus a false entry of expenditure limb in clause (ii). An addition made under s.28 or s.69B, or one the officer does not label at all, can still be undisclosed income for s.79A. Second, s.79A names unabsorbed depreciation under s.32(2) expressly, closing the argument that s.32(2) depreciation is not a 'loss'. Third, s.79A opens 'Notwithstanding anything contained in this Act', so ss.70, 71, 72, 73 and 74 all yield to it. The counterweight for open earlier years is that s.79A is prospective from AY 2022-23: the Madras High Court said so in M/s Sivasakthi Threads (23 January 2026), and for years before AY 2017-18 CBDT's own Circular No. 11/2019 accepts that even the s.115BBE(2) set-off bar did not operate. Note also that the survey carve-out is narrow — only s.133A(2A) surveys (the TDS/TCS verification survey) are outside s.79A.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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