CIT, IT v. SIS Live (2025) 305 Taxman 212 (Delhi)(HC)

S. 268A : Appeal-Application-Instructions-Tax effect of losses of earlier years which were not permitted to be carried forward was not to be taken into account to determine overall tax effect for purpose of filing appeal by revenue. [S.260A]

In terms of Circular No. 5/2024 and Circular No. 9/2024, where Assessing Officer had enhanced income of assessee to reflect assessed income, tax effect would be determined on amount of returned loss plus assessed income. Therefore, tax effect of losses of earlier years which were not permitted to be carried forward was not to be taken into account to determine overall tax effect for purpose of filing appeal by revenue.   (AY. 2018-19)

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