2025 (1) TMI 368

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....onfirming the action of Ld. AO in not allowing the setoff of accumulated deficit of Rs.5,66,68,630/- against the current year surplus and that too without any basis and without appreciating/considering the facts and circumstances of the case and in violation of principles of natural justice. 2. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in not allowing the setoff of accumulated deficit o Rs.5,66,68,630/- against the current year surplus, is illegal, bad in law and against the facts and circumstances of the case. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not allowing the depreciation as claimed by the assessee ....

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....nst the current year surplus and that too without any basis and without appreciating / considering the facts and circumstances of the case and in violation of principles of natural justice. To support his contention, he filed the following submissions:- "The only effective issue in the present appeal is not allowing the set off of accumulated deficit against the current year surplus. Ld. AO has computed income at Rs. 1,03,44,990/- but has not allowed the set off of accumulated deficit of Rs. 5,66,68,630/- as on 01.04.2015 which is allowable in view of the Hon'ble Supreme Court decisions referred the cases of CIT vs. Subros Educational Society, (2018) 96 taxmann.com 652 (SC), CIT vs. Subros Educational Society, (2022) 136 taxmann.com 236 (....