High Court dismisses appeals on export turnover expenses & set-off losses under section 10A - issues not substantial.

The High Court dismissed the appeals as the issues raised regarding the reduction of expenses from export turnover and the allowance of set-off of losses of earlier years before deduction under section 10A of the Act were not considered substantial questions of law based on precedents from previous decisions. The court referred to relevant cases such as CIT v. Tata Elxsi Ltd. and CIT v. Yokogawa India Ltd., ultimately concluding that the matters in question had already been settled.

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Issues:
1. Whether the expenses reduced from the export turnover should also be reduced from the total turnover.
2. Whether the set-off of losses of earlier years is allowed before deduction under section 10A of the Act.

Analysis:
1. The first issue raised in the appeal pertains to whether the expenses reduced from the export turnover should also be reduced from the total turnover. The court referred to a previous decision in the case of CIT v. Tata Elxsi Ltd. [2012] 349 ITR 98, where a similar matter was addressed. The court noted that the issue in question has already been settled by the aforementioned decision. Therefore, the court concluded that this question does not remain a substantial question of law.

2. Moving on to the second issue raised in the appeal regarding the allowance of set-off of losses of earlier years before deduction under section 10A of the Act, the court cited a previous decision in the case of CIT v. Yokogawa India Ltd. [2012] 341 ITR 385. It was mentioned that this matter was taken to the Apex Court, which disposed of the appeals in the case of CIT v. Yokogawa India Ltd. [2017] 391 ITR 274. Consequently, the court held that this issue also does not remain a substantial question of law.

In conclusion, considering the precedents set by previous judgments and the resolution of similar issues in the past, the High Court dismissed the appeals on both counts.

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