Set-off option under section 71(2) requires written election before losses are applied against short-term capital gains. Section 71(2) allows either-wide set off of losses against income under any head including capital gains or, by the assessee's election, restricts set off to income under the head Capital gains insofar as it relates to short term capital assets and other heads. The Board directs that any set off under the elected option must be supported by the assessee's written option and an explicit order sheet entry by the assessing officer confirming the option was exercised.
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Provisions expressly mentioned in the judgment/order text.
Set-off option under section 71(2) requires written election before losses are applied against short-term capital gains.
Section 71(2) allows either-wide set off of losses against income under any head including capital gains or, by the assessee's election, restricts set off to income under the head Capital gains insofar as it relates to short term capital assets and other heads. The Board directs that any set off under the elected option must be supported by the assessee's written option and an explicit order sheet entry by the assessing officer confirming the option was exercised.
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