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    <title>2025 (3) TMI 1973 - ITAT JAIPUR</title>
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    <description>Set-off of unabsorbed losses from a specified business under Section 73A was treated as allowable on the principle of consistency because the claim had been accepted for other assessment years and related appeals had succeeded. A 1070-day appeal delay arose from the assessee&#039;s advanced age, subsequent death, and the legal heir&#039;s later discovery of the adverse income-tax portal intimation. The limitation dismissal did not account for those circumstances. The appeal was restored, and the Assessing Officer was directed to rectify the Section 143(1) intimation and allow the set-off claim.</description>
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      <title>2025 (3) TMI 1973 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=470065</link>
      <description>Set-off of unabsorbed losses from a specified business under Section 73A was treated as allowable on the principle of consistency because the claim had been accepted for other assessment years and related appeals had succeeded. A 1070-day appeal delay arose from the assessee&#039;s advanced age, subsequent death, and the legal heir&#039;s later discovery of the adverse income-tax portal intimation. The limitation dismissal did not account for those circumstances. The appeal was restored, and the Assessing Officer was directed to rectify the Section 143(1) intimation and allow the set-off claim.</description>
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