(1.) IN this reference made under s. 256(1) of the IT Act, 1961 (hereinafter referred to as "the Act"), the INcome-tax Appellate Tribunal, Bangalore Bench, Bangalore (hereinafter referred to as the "Tribunal"), at the instance of the CIT, Karnataka- II, Bangalore, has referred the following questions of law for the opinion of this Court:
(2.) IN order to appreciate the questions referred to us, it is necessary to notice the facts as found by the Tribunal in the first instance.
(3.) SRI SRInivasan has urged that under s. 80J of the Act, a claim for relief must be made and quantified for the particular year and it is only then it can be carried forward for the subsequent year and set off.