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1984 (7) TMI 208
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....e income added under section 64 of the Income-tax Act, 1961 ('the Act'), against the loss incurred by the assessee. The admitted fact is that the assessee's own income from business and property as well as the other sources was determined at a loss of Rs. 50,582. To this amount, the ITO added the share of the income of the assessee's minor son from the firms, in which he was admitted to be a partn....
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....me-tax Act, 1961, which are not in pari materia. In particular, there is an Explanation which defines income which is to be added under section 64 to include loss, thus underlining the principle of set off of the amount added under section 64 with the other amounts of income of the assessee. If the loss to be added under section 64 could be set off against the other income of the assessee, we fail....