Appeal resolved favorably for assessee; software depreciation issue remanded for reconsideration by Tribunal.

The appeal is disposed of with most substantial questions of law resolved in favor of the assessee, except for the depreciation on software issue, which is remanded to the Tribunal for reconsideration. The Tribunal's reliance on prior orders and Supreme Court decisions significantly influenced the judgment. The AO is instructed to address issues in line with future Supreme Court rulings.

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Issues Involved:
1. Set-off of losses of STP/SEZ unit against other income.
2. Depreciation on software.
3. Exclusion of interest income, rental income, and other income for Section 10A deduction.
4. Re-computation of deduction under Section 10A.
5. Deduction under Section 10A for export turnover not remitted within six months.
6. Deduction under Section 10A for Bangalore undertaking established prior to 1993.
7. Allocation of corporate overhead to 80IB unit.
8. Deduction under Section 80IB for trading activity of monitors and printers.
9. Corporate overhead expenses for units claiming 80IC deduction.
10. Allocation of corporate expenses to SEZ developers undertaking for Section 80IA deduction.
11. Foreign tax credit entitlement.
12. Allocation of corporate expenses for 10A and non-10A units.

Detailed Analysis:

1. Set-off of losses of STP/SEZ unit against other income:
The Tribunal allowed the set-off of losses of STP/SEZ units against other income by relying on its previous order for the Assessment Year 2007-08. The Supreme Court in 'Commissioner of Income-Tax vs. Yokogawa India Ltd.' held that losses of STP units cannot be set off against profits of taxable units. Therefore, the first substantial question of law is answered in favor of the assessee.

2. Depreciation on software:
The Tribunal allowed the depreciation on software by following its previous order for the Assessment Year 2004-05. The revenue argued that the payment for software should be treated as royalty and disallowed under Section 40(a)(ia) of the Act. The Tribunal's decision was based on the case of 'Wipro Ltd.', which did not deal with the issue of royalty. The matter is remanded to the Tribunal for fresh decision considering the decision in 'Wipro Ltd.'.

3. Exclusion of interest income, rental income, and other income for Section 10A deduction:
The Tribunal set aside the exclusion of these incomes for Section 10A deduction by following its previous orders for the Assessment Years 2004-05 and 2007-08, remitting the matter to the Assessing Officer.

4. Re-computation of deduction under Section 10A:
The Tribunal set aside the recomputation of deduction under Section 10A by following the decision of the High Court in 'CIT vs. Tata Elxsi', which has not reached finality. The Tribunal's decision is upheld.

5. Deduction under Section 10A for export turnover not remitted within six months:
The Tribunal allowed the deduction under Section 10A for export turnover not remitted within six months, directing the Assessing Officer to exclude the amount remitted after six months from the export turnover for computing the deduction.

6. Deduction under Section 10A for Bangalore undertaking established prior to 1993:
The Tribunal decided in favor of the assessee for deduction under Section 10A for the Bangalore undertaking established before 1993, clarifying that income from expanded undertaking is eligible to the extent of extended capacity utilized.

7. Allocation of corporate overhead to 80IB unit:
The Tribunal directed the Assessing Officer not to allocate any corporate overhead to the 80IB unit over and above the allocation made by the assessee, following its previous orders.

8. Deduction under Section 80IB for trading activity of monitors and printers:
The Tribunal allowed the deduction under Section 80IB for trading activity of monitors and printers by relying on its previous orders.

9. Corporate overhead expenses for units claiming 80IC deduction:
The Tribunal allowed the allocation of corporate overhead expenses for units claiming 80IC deduction by relying on its previous orders for the Assessment Years 2004-05 and 2007-08.

10. Allocation of corporate expenses to SEZ developers undertaking for Section 80IA deduction:
The Tribunal allowed the allocation of corporate expenses to SEZ developers undertaking for Section 80IA deduction by relying on its previous orders.

11. Foreign tax credit entitlement:
The Tribunal allowed the claim for foreign tax credit by following the decision of the High Court in the assessee's own case for the Assessment Year 2003-04.

12. Allocation of corporate expenses for 10A and non-10A units:
The Tribunal set aside the allocation of corporate expenses for 10A and non-10A units by relying on its previous orders for earlier assessment years.

Conclusion:
The appeal is disposed of, with most substantial questions of law answered in favor of the assessee, except for the issue of depreciation on software, which is remanded to the Tribunal for fresh consideration. The Tribunal's reliance on previous orders and the Supreme Court's decisions in similar cases played a significant role in the judgment. The Assessing Officer is directed to decide the issues in accordance with the Supreme Court's future decisions.

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