Tribunal held that whether current year loss can be set off from the income declared under section 158BD is highly debatable hence such set off cannot be allowed by way of rectification. (AY. 2012-13)
Rakesh Kumar Pandita v. ACIT (2021) 207 DTR 473 / 91 ITR 65 (SN) / 214 TTJ 918 (SMC) (Delhi)(Trib.)
S. 154 : Rectification of mistake-Adjustment of current year loss-Income declared u/s. 158D of the Act-Debatable issue cannot be rectified. [S. 158BD]