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Commissioner Of Income-Tax, Ahmedabad vs Bhavnagar Trust Corporation (P.) Ltd. on 12 March, 1967

10. The law so laid down by the apex court in relation to Section 24(2) of the 1922 Act is equally applicable to an assessment under the Income-tax Act, 1961, having regard to the fact that the language employed in Section 72(1) is not materially different from what had been provided in Section 24(2) of the 1922 Act. Section 72(1) in its opening part refers to the head "Profits and gains of business or profession" and the loss determined under that head not being set off against income under any other head of income in accordance with the provisions of Section 71 and permits the carry forward of such loss to later assessment years. The set-off in those assessment years is to be "against the profits and gains, if any, of any business or profession carried on by him ..."
Gujarat High Court Cites 3 - Cited by 20 - Full Document

Western States Trading Co Ltd vs Commissioner Of Income Tax, Central ... on 18 January, 1971

4. Learned counsel for the Revenue submitted that that view of the Tribunal is erroneous. His submission was that the decision on which the assessee had relied before the Commissioner had been rightly distinguished by the Commissioner on the ground that the language of Section 24(2) of the Indian Income-tax Act, 1922, was materially different from that found in Section 72(1) of the Income-tax Act, 1961. The decision which had been cited before the Commissioner, but which was not followed by the Commissioner is Western States Trading Co. P. Ltd. v. CIT [1971] 80 ITR 21, a decision rendered by a three-judge Bench of the apex court.
Supreme Court of India Cites 10 - Cited by 33 - A N Grover - Full Document
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