Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
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