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1996 (8) TMI 163 - AT - Income TaxExtract: .......under the head Profits and gains from business or profession . Where the assessee does not have any positive income chargeable to tax under the aforesaid head, then in our opinion, there cannot be any application of sub-section (3). 9. With these observations, we upheld the order of the CIT(A). In the result, the appeal of the assessee is dismissed
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