The return of the assessee was processed u/s 143(1) and while computing the total income the loss of current year was adjusted. assessee filed an application u/s. 154 of the Act. The application was dismissed, which was affirmed by the CIT(A). On appeal the Tribunal held that whether expenditure or allowance, loss of current year can be set off against income declared u/s 115BBD is highly debatable issue hence dismissed. (dt. 22-10-2021) (AY. 2012-13).
Rakesh Kumar Pandita v. ACIT (2021) BCAJ-December-P. 46 (Delhi)(Trib.)
S. 154 : Rectification of mistake-Expenditure-Allowance-Loss of current year can be set off against income declared u/s 115BBD-Tax on certain dividends received from foreign companies-Debatable cannot be rectified. [S. 115BBD, 143(1)]