Rectification was allowed to permit set off of brought forward...

Rectification was allowed to permit set off of brought forward business losses and unabsorbed depreciation where a mistake apparent on the face of the record rendered the return inconsistent with an earlier rectified income figure. Tribunal held that although a claim for set off was not made in the original return and precedent bars allowing such a claim by letter during assessment, the revised returned income from the rectification order must govern when no fresh additions were made in the assessment conducted after seizure proceedings; consequently the returned income was to be treated like the earlier rectified return and the appeal was allowed.

---