Indisputably, the provisions of section 115BBE as existed prior to the amendment does not provide that the losses shall not be allowed to be set off against the income referred in section 115BBE and it is only to dispel the uncertainty prevailing on the issue, the provision was amended. A bare perusal of the provisions makes it abundantly clear that it cannot be applied retrospectively. Moreover, nowvidecircular No. 11/2019, the CBDT has clarified in unequivocal terms that the term 'or set off of any loss' was insertedvidethe Finance Act, 2016w.e.f.1.4.17 and therefore, an assessee is entitled to claim set off of loss against the income determined under section section 115BBE of the Act till the Assessment Year 2016-17. It is further clarified that the pending assessment and litigation on this issue shall be handled accordingly. In this view of the matter, the contention sought to be raised by the Revenue as aforesaid, cannot be countenanced by this Court.