This case will probably initiate closer examination in similar disputes, such as the case of Blackstone Capital Partners v. ACIT (Blackstone) before the Delhi High Court, and Sanofi Pasteur Holding v. Department of Revenue (Sanofi) case before Andhra Pradesh High Court.

The proposed amendment to Sections 72A and 72AA of ITA reflects government’s intent to curb tax avoidance through evergreening of losses.