https://www.taxtmi.com/caselaws?id=70369 Income included under section 64 of the Income-tax Act, 1961 was treated as the assessee's own income, and the Explanation to that provision was read as extending to loss as well. Read with section 14, the amount had to be placed under the appropriate head, and section 71 then permitted set-off against loss under another head. The contrary view based on section 16(3)(a) of the 1922 Act was held inapplicable because the 1961 Act was materially different, and where two interpretations conflicted, the one favourable to the assessee was preferred. The income was therefore liable to be set off against the assessee's loss. en-us Fri, 27 Jul 1984 00:00:00 +0530 Fri, 15 Apr 2011 17:51:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70369 Income included under section 64 of the Income-tax Act, 1961 was treated as the assessee's own income, and the Explanation to that provision was read as extending to loss as well. Read with section 14, the amount had to be placed under the appropriate head, and section 71 then permitted set-off against loss under another head. The contrary view based on section 16(3)(a) of the 1922 Act was held inapplicable because the 1961 Act was materially different, and where two interpretations conflicted, the one favourable to the assessee was preferred. The income was therefore liable to be set off against the assessee's loss. Case-Laws Income Tax Fri, 27 Jul 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70369