https://www.taxtmi.com/caselaws?id=445190 ITAT Nagpur ruled in favor of the assessee regarding set-off of losses against deemed income under section 69C. The AO had denied set-off claiming deemed income doesn't fall under any category in section 14. The tribunal held that SC precedents establish all income must be classified under section 14 heads, with deemed income from undisclosed sources assessable as "income from other sources." Since section 115BBE prohibiting such set-off was introduced only from AY 2017-18, the tribunal directed AO to allow set-off of losses against deemed income under section 69C. en-us Tue, 31 Oct 2023 00:00:00 +0530 Wed, 01 Nov 2023 16:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445190 ITAT Nagpur ruled in favor of the assessee regarding set-off of losses against deemed income under section 69C. The AO had denied set-off claiming deemed income doesn't fall under any category in section 14. The tribunal held that SC precedents establish all income must be classified under section 14 heads, with deemed income from undisclosed sources assessable as "income from other sources." Since section 115BBE prohibiting such set-off was introduced only from AY 2017-18, the tribunal directed AO to allow set-off of losses against deemed income under section 69C. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445190