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Set-off of losses against income from other sources u/s 70 - Applicability of provision of section 10B - petitioner had the status of EOU for a period of 5 years - The High Court upheld the petitioner's contention that Section 10B was not applicable to them as they were a 100% EOU. - The Court, after considering submissions and legal precedents, ruled in favor of the petitioner, declaring the notices and orders as invalid. The Court affirmed the petitioner's right to set off losses under Section 70 and upheld their interpretation of the law.