https://www.taxtmi.com/caselaws?id=271292 A beneficial CBDT circular on section 10A computation was treated as binding, and losses of an STPI/eligible unit could be aggregated under sections 70 and 71 before applying the deduction scheme; the resultant loss could be carried forward under section 72, so set-off against non-STPI profits was permitted. The article also notes that where a Japan branch carried on business outside India as a permanent establishment and the technical service payment was incurred for that overseas business, section 9(1)(vii)(b) excluded deemed accrual in India; no income being chargeable in India, no TDS obligation arose and disallowance under section 40(a)(i) could not be made. 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 A beneficial CBDT circular on section 10A computation was treated as binding, and losses of an STPI/eligible unit could be aggregated under sections 70 and 71 before applying the deduction scheme; the resultant loss could be carried forward under section 72, so set-off against non-STPI profits was permitted. The article also notes that where a Japan branch carried on business outside India as a permanent establishment and the technical service payment was incurred for that overseas business, section 9(1)(vii)(b) excluded deemed accrual in India; no income being chargeable in India, no TDS obligation arose and disallowance under section 40(a)(i) could not be made. Case-Laws Income Tax Fri, 22 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271292