CIT's Revision u/s 263: No Set-Off Claim Due to Lack of Positive Income, No Prejudice to Revenue.

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....Revision u/s 263 by CIT - Unabsorbed Depreciation or unabsorbed Business Loss - Even, assuming for a moment, the PCIT is right on his observation, but fact remains that brought forward unabsorbed depreciation can very well be examined by the AO when the assessee has claimed set off of unabsorbed depreciation against current year income in subsequent assessment years. Since, there is no positive income for the impugned assessment year and the assessee has not claimed set off of unabsorbed depreciation there is no prejudice is caused to the Revenue - AT....