https://www.taxtmi.com/caselaws?id=375984 ITAT Delhi ruled in favor of the assessee on section 10A exemption matters. The tribunal upheld CIT(A)'s decision that brought forward business losses and unabsorbed depreciation from non-eligible business units cannot be adjusted while calculating section 10A exemption for STPI units. Following Yogokawa India Ltd precedent, section 10A deduction must be taken before setting off brought forward losses. Regarding section 14A disallowance, the tribunal deleted additions for indirect expenses as the assessee proved no borrowed funds were diverted to mutual fund investments. However, administrative expenses at 5% of average investment were confirmed under Rule 8D(iii), as some management expenditure for exempt income investments is inevitable. The appeal was decided against revenue. en-us Tue, 15 Jan 2019 00:00:00 +0530 Mon, 21 Jul 2025 10:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375984 ITAT Delhi ruled in favor of the assessee on section 10A exemption matters. The tribunal upheld CIT(A)'s decision that brought forward business losses and unabsorbed depreciation from non-eligible business units cannot be adjusted while calculating section 10A exemption for STPI units. Following Yogokawa India Ltd precedent, section 10A deduction must be taken before setting off brought forward losses. Regarding section 14A disallowance, the tribunal deleted additions for indirect expenses as the assessee proved no borrowed funds were diverted to mutual fund investments. However, administrative expenses at 5% of average investment were confirmed under Rule 8D(iii), as some management expenditure for exempt income investments is inevitable. The appeal was decided against revenue. Case-Laws Income Tax Tue, 15 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375984