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Explainer3 min readPublished

The deferred tax asset recognised on a loss carryforward with nothing behind it

An illustrative, composite walkthrough of a deferred tax asset recognised against accumulated tax losses with no supporting profitability projection, caught when the audit asked for the forecast management said it had relied on.

This is a composite, illustrative scenario, not an account of a named client. The company had recognised a deferred tax asset of roughly ₹1.1 crore against accumulated business losses carried forward from the two preceding years, on the basis that sufficient future taxable profit would be available to utilise those losses within the permitted carryforward period. When the audit asked for the profitability projection management said it had relied on in reaching that conclusion, no such document existed — the recognition had been based on a general verbal expectation that the business would turn around, not on any board-approved forecast, budget, or sensitivity analysis.

Why this is a recognition problem, not just a documentation gap

Recognising a deferred tax asset on carried-forward losses requires convincing evidence that sufficient future taxable profit will be available against which the asset can be utilised — a higher bar than for other temporary differences, precisely because a history of recent losses is itself evidence pointing the other way. Without a profitability projection to examine, there was nothing to test the recognition against: no revenue assumptions, no margin assumptions, no basis to assess whether 'sufficient future taxable profit' was actually probable or simply hoped for.

What the audit asked for, and what came back

  1. 01Requested the board-approved budget or forecast used to support recognitionNone existed for the period covering the loss carryforward window — only an informal operating plan for the next year alone, which did not even cover the full utilisation period.
  2. 02Checked the company's actual track record against its own past budgets, where any existedThe one prior budget that could be found had itself not been met, undermining confidence in an unwritten verbal expectation of a turnaround.
  3. 03Assessed whether any other convincing evidence existedA large committed order from a new customer, signed after the year end, was offered as support — relevant, but insufficient on its own to project profitability sufficient to absorb the full loss carryforward within the available period.
  4. 04Quantified the asset recognised against what could actually be supportedUsing only the evidence that could be substantiated, a portion of the deferred tax asset was supportable; the remainder was not.
Deferred tax asset recognised versus what the evidence supported
Amount
Deferred tax asset recognised by management₹1.1 crore
Supportable against the new customer order and realistic near-term profitabilityRoughly ₹0.4 crore
Proposed write-down for lack of convincing evidenceRoughly ₹0.7 crore
Deferred tax asset recognised versus what the evidence supported

What went into the file

  • The request for a profitability projection and the documented absence of one, as the starting point of the finding.
  • The assessment of the new customer order as partial, not full, support for recognition.
  • The proposed adjustment and management's revised recognition after the discussion, scaled back to the supportable portion.
  • A recommendation that any deferred tax asset recognised against loss carryforwards going forward be supported by a board-approved forecast at the point of recognition, not reconstructed after the fact when the auditor asks.

Regulatory requirement

Recognition of a deferred tax asset for unused tax losses requires convincing evidence, applying a more demanding standard than for ordinary temporary differences, that sufficient future taxable profit will be available. A recent history of losses is itself evidence against recognition unless there is specific, documented evidence to the contrary — a verbal expectation of a turnaround does not meet that bar.

This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.

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