Explain the term "return of loss" under the Income-tax Act, 1961. Can any loss be carried forward even if return of loss has not been filed as required under section 139(3) of Income-tax Act, 1961?

A return of loss is a return which shows certain losses under Income-tax under various head of Incomes. Section 80 of the Income tax Act, 1961 provides that the losses specified therein cannot be carried forward, unless such losses are determined in pursuance of return filed under the provisions of section 139(3) of the Income tax Act, 1961. Section 139(3) of the Income tax Act, 1961 states that to carry forward the losses specified therein; the return should be filed within the time specified in section 139(1) of the Income tax Act, 1961. Following losses are covered by section 139(3) of the Income tax Act, 1961: Business loss to be carried forward under section 72(1); Speculation business loss to be carried forward under section 73(2); Loss from specified business to be carried forward under section 73A(2); Loss under the head "Capital Gains" to be carried forward under section 74(1); and Loss incurred in the activity of owning and maintaining race horses to be carried forward under section 74A(3). However, loss from house property to be carried forward under section 71B and unabsorbed depreciation under section 32 can be carried forward even if return of loss has not been filed as required under section 139(3) of the Income tax Act, 1961.