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ITA No s . 2 09 9/ Mu m/ 2 01 7 & 60 4 8/ Mu m/ 2 01 7

11. We have to interpret the provisions of any statute to make the same workable to the logical ends. As per the provisions of sub-

section (5) to section 139, in both the situations where the assessee has filed the return of positive income as well as return of loss at the first instance as per the time limit prescribed and subsequently, files the revised return then the revised return is treated as valid return. In the present case, as the assessee filed its original return declaring the positive income and hence, in our opinion, subsequent revised return is valid return also and the assessee is entitled to carry forward of 'long-term capital loss'. Sub-sections (1) and (3) of section 139 provides for the different situations and in our opinion, there is no conflict in applicability of both the provisions as both the provisions are applicable in the different situations. We are, therefore, of the opinion that there is no justification to deny the assessee to carry forward the loss. We, accordingly, direct the Assessing Officer to allow the assessee to carry forward the loss."