https://www.taxtmi.com/caselaws?id=782659 Eligible software technology park unit deductions under section 10A are computed at the undertaking level before general aggregation and set-off provisions apply, so losses of one eligible unit cannot be offset against income from other units at that stage. Payments for international private leased circuits were not royalty for the relevant years because retrospective domestic amendments could not enlarge the DTAA definition, so section 40(a)(i) disallowance did not apply. The India-USA DTAA non-discrimination clause barred a disallowance mechanism operating only against non-resident payments. Interest on staff loans and scrap-sale income retained the necessary business nexus for section 10A/10B deduction. Interest under section 234D was sustained on excess refund. en-us Tue, 25 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782659 Eligible software technology park unit deductions under section 10A are computed at the undertaking level before general aggregation and set-off provisions apply, so losses of one eligible unit cannot be offset against income from other units at that stage. Payments for international private leased circuits were not royalty for the relevant years because retrospective domestic amendments could not enlarge the DTAA definition, so section 40(a)(i) disallowance did not apply. The India-USA DTAA non-discrimination clause barred a disallowance mechanism operating only against non-resident payments. Interest on staff loans and scrap-sale income retained the necessary business nexus for section 10A/10B deduction. Interest under section 234D was sustained on excess refund. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782659