Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
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