Unabsorbed Depreciation Can Offset Long-Term Capital Gains Even with Late Filing, Section 32(2) Prevails Over Section 139(1.

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....Disallowing set-off of unabsorbed depreciation against income of long Term Capital Gain - belated filing of returns of income - the condition of filing return of income within the time prescribed u/s. 139(1) of the Act is not applicable for the provisions of sec. 32(2).....