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2012 (6) TMI 211 - AT - Income TaxSet off of business loss - denial on ground of change in shareholding of the company - losses of AY 98-99 purported to set off against income of AY 2006-07 - assessee contended that A.O. was not competent to forbid the set off of the brought toward business loss for A.Y. 1998-99 against the business income for the current year because the so called change in the shareholding pattern took place in an earlier year and not the previous year relevant to the assessment year under consideration - Held that:- It is noticed that the contention now raised before us has been taken for the first time. Since additional evidence as well as this argument were admittedly not before the authorities below , we are of the considered opinion that it will be in the fitness of things if this aspect is sent back to the AO for taking a fresh decision after considering all the relevant material - Decided partly in favor of assessee for statistical purposes.
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