https://www.taxtmi.com/caselaws?id=262317 The Madras HC explained that section 80-IA is a profit-linked deduction for an eligible business and that sub-section (5) creates a limited fiction for computing that deduction as if the eligible business were the only source of income. That fiction cannot be extended to reopen losses or depreciation already absorbed and set off in earlier years. Where the assessee had exercised the section 80-IA(2) option and the earlier losses stood adjusted, those losses could not be notionally carried forward again to reduce the deduction. The assessee was therefore entitled to the deduction, and the Revenue could not rework the prior set-off losses under section 80-IA(5). en-us Thu, 23 Jul 2015 00:00:00 +0530 Fri, 07 Aug 2015 06:37:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262317 The Madras HC explained that section 80-IA is a profit-linked deduction for an eligible business and that sub-section (5) creates a limited fiction for computing that deduction as if the eligible business were the only source of income. That fiction cannot be extended to reopen losses or depreciation already absorbed and set off in earlier years. Where the assessee had exercised the section 80-IA(2) option and the earlier losses stood adjusted, those losses could not be notionally carried forward again to reduce the deduction. The assessee was therefore entitled to the deduction, and the Revenue could not rework the prior set-off losses under section 80-IA(5). Case-Laws Income Tax Thu, 23 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262317