2002 (9) TMI 35

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..... , on the facts and in the circumstances of the case, the Tribunal was right in confirming the action of the Assessing Officer in rejecting section 154 petition in spite of the background that section 154 petition was filed against section 143(1) intimation ? (ii) Whether, on the facts and in the circumstances of the case, the Tribunal was right in confirming the action of the Assessing Officer in .....

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..... batable matter and that section 154 could not be invoked to deal with such matter. While it is provided in the Explanation to section 64, that for the purposes of the section, 'income" is to be read as including "loss", there is no such Explanation in section 161(1A). As to whether the term "income" in section 161(1A) should be read as including loss is clearly a debatable issue and it cannot be .....

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