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For the purpose of carrying forward the loss in terms of section 72 read with section 80 of the Act, in a case where search operations have been conducted under section 132 of the Act, the time to file the return within the meaning of section 139(3) of the Act has to be regarded as the reasonable time afforded by the consequent notice under section 153A(1)(a) of the Act.
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When search operations are conducted under section 132 of the Act, the obligation of the assessee to file any return remains suspended till such time that a notice is issued for such purpose under section 153A(1)(a) of the Act. If the return is filed by the assessee within the reasonable time permitted by such notice under section 153A(1)(a) of the Act, such return would then be deemed to have been filed within the time permitted under section 139(1) of the Act for the benefit under section 139(3) of the Act to be availed of by the assessee.
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The consideration that the loss in any year may be carried forward to the subsequent year and set off against the profits and gains in the subsequent year is a question that has to be determined by the assessing officer who deals with the assessment of the subsequent year.