ALISHAN STEELS (P)LTD,KOLKATA vs. DCIT, CIRCLE-1(1), KOLKATA
In the result, both the appeals of the assessee are partly allowed
ITA 1001/KOL/2023[2015-16]Status: HeardITAT Kolkata01 Jan 2024AY 2015-16
Bench: Shri Sanjay Garg & Shri Girish Agrawal
For Appellant: Shri K. M. Roy, FCA & Shri B. K. Agarwal, FCAFor Respondent: Shri Kapil Mondal, Addl. CIT, DR
Section 115BSection 143(3)Section 147Section 148Section 14ASection 40A(2)(b)Section 68
69D."
The intention of the legislature in introducing the amendment, as stated in the explanatory note, is to avoid unnecessary litigation and to expressly provide that no set off of any loss shall be allowable in respect of income under section 68. Therefore, it has to be held that, as on the relevant date of the assessment, there