The assessee claimed set-off of losses of Rs. 4.893 crores carried forward from the agricultural income-tax assessments of the amalgamated company. The assessees claim was rejected by the Assessing Officer on the ground that there was no provision similar to section 72A of the 1961 Act in the 1991 Act, and that section 12 of the 1991 Act did not authorise set-off of carried forward unabsorbed loss of the amalgamated company in the assessment of the amalgamating company, namely, the assessee. The Assessing Officer also found that the loss pertained to the period beyond 8 years and that the scheme of amalgamation approved by the High Court did not provide for set-off of carried forward loss of the amalgamated company in the computation of agricultural income of the amalgamating company under the 1991 Act. Order of Assessing Officer was affirmed by the Tribunal. On revision the Court held that  set-off of carried forward loss in the computation of agricultural income was a process exclusively within the domain of the Assessing Officer under the 1991 Act. Since the only provision applicable was section 12 of the Kerala Agricultural Income-tax Act, 1991, which did not authorise set-off in this case, the assessee was rightly found to be ineligible for the benefit by the Tribunal. Further, the assessee had not made the claim before the Income-tax Officer under the 1961 Act in the computation of income from manufacture of rubber under rule 7A of the 1962 Rules and that Officer had no occasion to consider the tenability of the claim.  (AY. 2006-07)