Long term shares

Kind attention: Mr Hardik

In CIT vs. Harprasad 99 ITR 118 (SC) it was held capital loss incurred in a year when capital gains were not exigible to tax cannot be set against capital gains in subsequent years. In Ramjilal Rais 58 ITR 181 (All) & Thiagarajan 129 ITR 115 (Mad) it was held that loss from sources that were exempt from tax cannot be set off. A contrary view has been taken in Royal Calcutta Turf Club 144 ITR 709 (Cal).

I appreaciate your views...........

but all my Friends can anybody display me?....  Where are those section(set off & Carried Forward) include exmept incomes?

Think Guys then Answer.......

It is a loop hole of Act. In this matter no tax applies but exempt gain should always carried forward and set off againt exempt loss till it comes to an end.

Some people think that why these exempt gain should be carried forward Right?