Bharat Infra Projects Limited ("BIPL") is a listed Indian public limited company engaged primarily in the engineering, procurement and construction…
CA Final · Direct Tax Laws and International Taxation · RTP · November 2026
Bharat Infra Projects Limited ("BIPL") is a listed Indian public limited company engaged primarily in the engineering, procurement and construction of Hybrid Annuity Model highway projects and related infrastructure works, and it also owns and operates renewable energy generating activities of its own.During the previous year 2025-26, BIPL continued its core construction operations. In respect of one long-term Hybrid Annuity Model highway contract, which commenced on 1st April 2025, the following are the particulars: Particulars Amount (₹) Total contract price inclusive of retention money of ₹ 18 crore ₹480 crores Estimated total contract costs ₹400 crores Net contract costs as recorded in the books of BIPL after reducing ₹ 4 crores of interest earned on temporary deployment of the mobilisation advance ₹256 crores Amount billed up to 31st March, 2026 ₹285 crores With effect from 1st April 2025, SRPG, a wholly owned solar and renewable power generation subsidiary of BIPL amalgamated into BIPL under a scheme of amalgamation satisfying all the conditions of section 72A.On 15th December 2025, BIPL acquired, commissioned and put to use certain solar power generating systems. The details of which are as follows: Particulars Amount (₹) Cost of acquisition and installation ₹90 crores Subsidy from the Ministry of New and Renewable Energy directly relatable to the cost of the solar power generating systems ₹22 crores Written down value, as on 1st April, 2025, of the block of assets of BIPL in which the said systems fall ₹20 crores Written down value, as on 1st April, 2025, of the corresponding block of the SRPG, transferred to BIPL under the scheme of amalgamation ₹30 croresIn March 2026 the Assessing Officer issued a notice under section 148 for Assessment Year 2024-25 in the name of the erstwhile amalgamating subsidiary. BIPL had duly intimated the fact and the effective date of the amalgamation to the Assessing Officer, and the Assessing Officer was aware thereof before issuing the notice. Therefore, BIPL did not participate in the proceedings pursuant to the notice and objected to it.Following the amalgamation and increased funding requirements, BIPL reviewed its capital allocation strategy in order to reduce leverage and to fund future projects and decided to monetise one of its undertakings located in Punjab State (established in the year 2018) for Highway Projects by way of a slump sale. The particulars are given below: Particulars ₹ crores Actual Monetary consideration received 170 Fair market value of Equity shares of the transferee received as consideration 40 Written down value as per Income-tax Rules, 1962 of the Depreciable assets of the undertaking 85 Book value of the depreciable assets of the undertaking 95 Book value of other assets of the undertaking (not being land, shares and securities, jewellery and artistic work) 35 Book value of the land forming part of the undertaking 55 Stamp duty value of the land forming part of the undertaking 70 Book value of liabilities of the undertaking 45 The tax attributes inherited on amalgamation and the business profit of BIPL for the year are as follows: Particulars ₹ crores Business profit of BIPL for the previous year 2025-26, computed under the head "Profits and gains of business or profession" as per the Income-tax Act. 96 Accumulated business loss of the amalgamating company, being an ordinary business loss not attributable to any special deduction. Such Business loss was first computed for Assessment Year 2021-22, and no part of it had been set off up to 31st March, 2025 48 Unabsorbed normal depreciation of A.Y. 2024-25 19 Unabsorbed capital expenditure on scientific research related to the business carried on transferred to BIPL, under the scheme of amalgamation 7 BIPL had exercised the option under section 115BAA in assessment year 2025-26, and that option continues to be in force.
Suggested Answer and Working Notes:
Correct Answer: Option (B)
Yes, BIPL can carry forward and set-off the accumulated losses of SRPG upto Assessment Year 2029-30
Topics: Business Restructuring, Capital Gains, Business Income (PGBP)
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