assessee for the earlier years be not considered for set off and carry
forward in view of change in shareholding pattern of the company ... carry forward of
accumulated business losses of the past years and set off under Section 79 of the
Act, the AO did not accept
under section 139(1) , the
forward and set-off
assessee forfeits the right to claim carry forward set of such
loss. The binding authority ... precedent and not a
mere procedural formality. Accordingly, the denial of set-off
set by the
CPC and its affirmation
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Equivalent citations: [2005
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