https://www.taxtmi.com/caselaws?id=327965 For deduction under Section 80-IA, earlier years' losses that were already absorbed against other income cannot be notionally brought forward and adjusted against the profits of the eligible business. The statutory fiction in Section 80-IA(5) applies only to computation of deduction from the initial assessment year onward and does not permit reopening exhausted losses from prior years. The reasoning follows the settled Chapter VI-A principle that profit-linked incentives do not authorise a notional recomputation of losses once they have been set off. The issue is answered in favour of the assessee and against the Revenue. en-us Mon, 25 Apr 2016 00:00:00 +0530 Wed, 10 Aug 2016 18:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327965 For deduction under Section 80-IA, earlier years' losses that were already absorbed against other income cannot be notionally brought forward and adjusted against the profits of the eligible business. The statutory fiction in Section 80-IA(5) applies only to computation of deduction from the initial assessment year onward and does not permit reopening exhausted losses from prior years. The reasoning follows the settled Chapter VI-A principle that profit-linked incentives do not authorise a notional recomputation of losses once they have been set off. The issue is answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Mon, 25 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327965