Court Rules Interest on FDs and NSCs Not Debatable for Business Loss Set-Off u/s 72 in Section 154 Proceedings.

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....Rectification of mistake - set off of the carry forward business loss denied - the issue as to whether the said income earned by way of interest on Fixed Deposits, NSCs, would be available to the assessee to seek for set off as business loss or u/s 72 of the Act is a debatable issue and as such we are of the considered view that said issue could not have been gone into in a proceeding u/s 154 - HC....