https://www.taxtmi.com/caselaws?id=260175 The Delhi High Court followed its earlier Division Bench rulings and noted that income of a Section 10A-eligible unit must be excluded before inter-head and intra-head set-off provisions are applied. On that construction of the statutory scheme, losses of the eligible unit could not be set off against profits of other units while computing total income. The CBDT circular relied on by the assessee did not override the binding prior decisions or alter the statutory treatment of Section 10A income, so the set-off was treated as impermissible and the issue favoured the Revenue. en-us Wed, 20 May 2015 00:00:00 +0530 Thu, 04 Jun 2015 08:22:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260175 The Delhi High Court followed its earlier Division Bench rulings and noted that income of a Section 10A-eligible unit must be excluded before inter-head and intra-head set-off provisions are applied. On that construction of the statutory scheme, losses of the eligible unit could not be set off against profits of other units while computing total income. The CBDT circular relied on by the assessee did not override the binding prior decisions or alter the statutory treatment of Section 10A income, so the set-off was treated as impermissible and the issue favoured the Revenue. Case-Laws Income Tax Wed, 20 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260175