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    <title>2015 (8) TMI 273 - MADRAS HIGH COURT</title>
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    <description>Section 80-IA&#039;s deeming fiction is limited to computing the profits of the eligible business during the deduction period and does not authorise reopening earlier years&#039; losses or depreciation that have already been set off against other income. Prior losses absorbed before the initial assessment year cannot be notionally carried forward and recomputed for deduction purposes. Applying that principle, the deduction was held available without such notional adjustment, and the issue was answered in favour of the assessee and against the Revenue.</description>
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      <description>Section 80-IA&#039;s deeming fiction is limited to computing the profits of the eligible business during the deduction period and does not authorise reopening earlier years&#039; losses or depreciation that have already been set off against other income. Prior losses absorbed before the initial assessment year cannot be notionally carried forward and recomputed for deduction purposes. Applying that principle, the deduction was held available without such notional adjustment, and the issue was answered in favour of the assessee and against the Revenue.</description>
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