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    <title>Section 71(2) allows set-off of business losses against other income heads without sequence restrictions, supporting tax planning</title>
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    <description>The ITAT allowed the assessee&#039;s appeal, holding that section 71(2) of the Income Tax Act permits the set-off of business losses against income from other sources, including capital gains, without prescribing a sequence for such set-off. Since no business income existed for the year, section 70, which mandates intra-source loss set-off, was inapplicable. The tribunal clarified that the assessee&#039;s method of setting off losses against income under different heads constituted legitimate tax planning within the statutory framework. Consequently, the deduction under Chapter VI-A disallowed by the Assessing Officer was directed to be granted as claimed by the assessee.</description>
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    <pubDate>Fri, 11 Jul 2025 08:39:54 +0530</pubDate>
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      <title>Section 71(2) allows set-off of business losses against other income heads without sequence restrictions, supporting tax planning</title>
      <link>https://www.taxtmi.com/highlights?id=90373</link>
      <description>The ITAT allowed the assessee&#039;s appeal, holding that section 71(2) of the Income Tax Act permits the set-off of business losses against income from other sources, including capital gains, without prescribing a sequence for such set-off. Since no business income existed for the year, section 70, which mandates intra-source loss set-off, was inapplicable. The tribunal clarified that the assessee&#039;s method of setting off losses against income under different heads constituted legitimate tax planning within the statutory framework. Consequently, the deduction under Chapter VI-A disallowed by the Assessing Officer was directed to be granted as claimed by the assessee.</description>
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