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<h1>Companies under tonnage tax scheme cannot offset pre-existing shipping losses against non-shipping income under Section 115VM</h1> Section 115VM of the Income Tax Act, 1961 governs loss exclusion for companies under the tonnage tax scheme. Pre-existing losses attributable to tonnage tax business are treated as if set off against relevant shipping income during the tonnage tax period. These losses cannot be offset against non-shipping income after the company opts for tonnage taxation. Loss apportionment must be done reasonably to determine applicable amounts. The provision was inserted by Finance Act 2004, effective from April 1, 2005.