1986 (5) TMI 39

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....appeal reads as follows: "On the facts and in the circumstances of the case and in law, the ld. CIT (A) erred in allowing the carry forward of loss though the return was not filed within the time limit prescribed under s. 139 (1)." The assessee, a company in which public are not substantially interested, filed its return on 14th Sept., 1983 declaring a loss of Rs. 36,71,222. The ITO determin....

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.... the ld. representative of the assessee Shri Panjwani brought to our notice the instructions of CBDT contained in the Circular dt. 14th March, 1985 under which it has been clarified that the instructions dt. 20th Sept., 1983 (relied upon by the ITO) would be effective from asst. yr. 1984-85 only. In this view of the matter, therefore, we do not see any reason to interfere with the decision of the ....