https://www.taxtmi.com/caselaws?id=271292 Section 10A losses of an eligible STPI unit may be aggregated and set off against profits of a non-STPI unit under the ordinary computation provisions before applying the deduction framework. A beneficial CBDT circular on computation and carry-forward of such losses binds departmental authorities. Payments for technical services made by an overseas permanent establishment for its business fall within the exclusion for income not deemed to accrue or arise in India. Where the recipient has no income chargeable in India, no tax deduction obligation arises and disallowance for non-deduction cannot be sustained. en-us Fri, 22 Jan 2016 00:00:00 +0530 Sun, 31 Jan 2016 23:15:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271292 Section 10A losses of an eligible STPI unit may be aggregated and set off against profits of a non-STPI unit under the ordinary computation provisions before applying the deduction framework. A beneficial CBDT circular on computation and carry-forward of such losses binds departmental authorities. Payments for technical services made by an overseas permanent establishment for its business fall within the exclusion for income not deemed to accrue or arise in India. Where the recipient has no income chargeable in India, no tax deduction obligation arises and disallowance for non-deduction cannot be sustained. Case-Laws Income Tax Fri, 22 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271292