COMMISSIONER OF INCOME-TAX, PUNJAB vs KULU VALLEY TRANSPORT CO. (P) LTD.

The Supreme Court held that under the Income-tax Act, 1922, a voluntary return showing loss can be filed at any time before assessment, as per Section 22(3). The Court ruled that the income-tax Officer must consider such returns and determine the losses, allowing the carry forward of losses under Section 24(2). The appeal by the Commissioner of Income-tax was dismissed, affirming the High Court's decision that the assessee was entitled to carry forward the losses despite the late filing of the return.