Dismissing the appeal of the Revenue the Court held that on appeal the  Tribunal held  that it was not within the remit of the AO, dealing with the assessment year in issue, to make an observation concerning an aspect that would fall within the jurisdiction of the AO, when the aspect concerning carry forward and set off losses would come to the fore. A textual reading of S. 79 makes it evident that it does not empower an AO, who exercises jurisdiction qua a particular assessment year, to place limitations on the adjudicatory powers of the AO who would be called upon to deal with the matter in subsequent years. Furthermore, there is another facet of the matter that, Revenue’s counsel has failed to address while invoking the provisions of S 79. This concerns the right of the assessee, albeit as per law, to carry forward ‘unabsorbed depreciation’ and ‘capital losses’. A perusal of s. 79 would show that unabsorbed depreciation and capital losses do not fall within its scope and ambit. There is no practical efficacy in the assessee carrying forward business losses, unabsorbed depreciation, and capital losses unless there is a possibility of setting off those losses in the future, albeit subject to the provisions of the Act. These are the aspects that the concerned AO would examine in the relevant assessment year in which such set off is claimed. Order of Tribunal is affirmed. Relied on CIT v. Manmohan Das (1966) 59 ITR 699 (SC). (AY. 2014-15)