Law: Income Tax Act, 1922

Section: 24(2)

Income-tax Act (XI of 1922)-----S. 24(2)-Losses against profits in subsequent years-Set-off of ­Assessee challenging order of Commissioner. Income-tax refusing to interfere with orders of assessment for years 1964-65, 1965-66 and 1967-68-Assesses alleging acquiring vested right under S. 24(2) for carrying forward excess amount of losses found in year 1962-63 for adjustment against profits and gains ire subsequent years-Assessment orders for years 1953-64 to 1967-68 appealable - Petitioner preferred appeals only in respect of assessment order for year 1966-67 and 1967-68 but question of carrying forward losses of previous years not agitated therein-Held, orders of assessment became final under law arid in circumstances, refusal by Commissioner of income-tax to interfere based on sound and cogent reasons. Grindlays Bank v. Commissioner of Income-tax I. L. T. L. C. No. 157 JUDGMENT SAEEDUZZAMAN SIDDIQUI, J,--The petitioner has challenged in this petition the revisional order of Commissioner of Income-tax, Central Zone, Karachi dated 3-9-1979, whereby he refused to interfere with the orders of assessment 3r the years 1964-65, 1965-66 and 1967-68. The order is assailed by the learned counsel for the petitioner or: the sole ground that the petitioner had acquired a vested right under section 24(2) of the Income-tax Act for carrying forward the excess amount of losses found in the year 1962-63, for adjustment against the profits and gains in subsequent years. The admitted position in the case is that the petitioner which is a foreign based company was assessed to Income-tax in the year 1962-63 as a resident and ordinary resident company in Pakistan and therefore the world income and losses of the company for that year were taken into account. The company in that year was found to have made a profit of 34,242 from its business in Pakistan as against the world losses of Rs. 16,62,565 with the result the total world losses for that year after deducting the profit were found to Rs. 16,29,319. However, in the sub-sequent years namely 1963-64, 1964-65, 1965-66, 1966-67 and 1967-68 the company was assessed as a non-resident Company and as such the world losses found in the…

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