https://www.taxtmi.com/caselaws?id=258493 Section 80-IA deduction is a profit-linked incentive, and the deeming fiction in sub-section (5) applies only to computing the eligible business's deduction for the relevant years. Earlier losses that have already been set off against other income cannot be reopened, notionally carried forward again, or adjusted a second time for recomputation of the deduction. The Court followed its earlier view and the Rajasthan High Court's reasoning, holding that the fiction is confined to its limited purpose and does not permit revival of absorbed losses. The resulting position favoured the assessee and rejected the Revenue's attempt to rework the deduction base. en-us Tue, 07 Apr 2015 00:00:00 +0530 Sat, 11 Apr 2015 00:58:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258493 Section 80-IA deduction is a profit-linked incentive, and the deeming fiction in sub-section (5) applies only to computing the eligible business's deduction for the relevant years. Earlier losses that have already been set off against other income cannot be reopened, notionally carried forward again, or adjusted a second time for recomputation of the deduction. The Court followed its earlier view and the Rajasthan High Court's reasoning, holding that the fiction is confined to its limited purpose and does not permit revival of absorbed losses. The resulting position favoured the assessee and rejected the Revenue's attempt to rework the deduction base. Case-Laws Income Tax Tue, 07 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258493