Commissioner Of Income Tax, Gujarat vs Cellulose Products Of India Ltd on 4 September, 1991
In view of the Full Bench decision of this court in CIT v. Cellulose Products of India Ltd. [1985] 151 ITR 499, it was not seriously disputed before us that it was open to the assessee to urge before the Tribunal that the Appellate Assistant Commissioner had erred in holding that the deficit of Rs. 2,739 in the assessment year 1971-72 and of Rs. 5,881 in the assessment year 1972-73 incurred by the assessee cannot be available for set off against the other income while computing the total income, when such point was not urged before the Appellate Assistant Commissioner.