CIT's Use of Section 263 Deemed Unjustified for Offsetting Business Losses Against Unexplained Income u/s 71.

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....Revision u/s 263 - business loss cannot be set off against other sources as per sec.71 - there is a divergent view on the issue of set off of business loss out of unexplained income u/s. 71 while computing the income of assessee - CIT is not justified in exercising the jurisdiction u/s. 263 - AT....