Dismissing the appeal of the revenue the Court held that ; the rationale for the amendment of section 32(2) that the restriction against set off and carry forward limited to eight years, beyond which the benefit could not be claimed under the provisions of the 1961 Act, was for the reasons deemed appropriate by Parliament. The limit was imposed in the year 1996 through the Finance (No. 2) Act, 1996. Had the intention of Parliament been really to restrict the benefit, of unlimited carry forward prospectively, there were more decisive ways of doing so, such as, an expressed provision or an exception or proviso. The absence of any such legislative device meant that the provision had to be construed in its own terms and not so as to restrict the benefit or advantage it sought to confirm. No question of law arose. Provision to be construed in its own terms , benefit or advantages not to be restricted ( AY. 2010-11)