https://www.taxtmi.com/caselaws?id=8909 Whether a registered firm may carry forward and set off unabsorbed depreciation and losses for assessment of firm tax: held that s.32(2) and s.75(2) allocate depreciation and losses to partners, leaving nothing for the firm to carry forward; permitting carry-forward for firm tax would create incongruous dual assessments and is not contemplated by the Act. Alternatively, if firm tax were treated as separate, no statutory provision authorises carry-forward/set-off for the firm. Reasoning based on the specific language of ss.32(2) and 75(2) and the absence of any contrary provision. Outcome: claim rejected; HC affirms Commissioner's refusal and dismisses petition with costs. en-us Fri, 14 Jul 1972 00:00:00 +0530 Tue, 20 Jan 2026 11:46:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8909 Whether a registered firm may carry forward and set off unabsorbed depreciation and losses for assessment of firm tax: held that s.32(2) and s.75(2) allocate depreciation and losses to partners, leaving nothing for the firm to carry forward; permitting carry-forward for firm tax would create incongruous dual assessments and is not contemplated by the Act. Alternatively, if firm tax were treated as separate, no statutory provision authorises carry-forward/set-off for the firm. Reasoning based on the specific language of ss.32(2) and 75(2) and the absence of any contrary provision. Outcome: claim rejected; HC affirms Commissioner's refusal and dismisses petition with costs. Case-Laws Income Tax Fri, 14 Jul 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8909