2020 (1) TMI 1159

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....nt. 2. This appeal under Section 260A of the Income Tax Act, 1961 ("the Act" for short) has been preferred by the revenue against the order dated 5.5.2016 passed by the Income Tax Appellate Tribunal, Pune Bench "A", Pune ("Tribunal" for short) in Income Tax Appeal No. 1356/PN/2014 for the assessment year 2007-08.   3. Revenue has projected the following three questions as substantial questi....

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....held that there is no bar in Section 10A of the Act to prohibit the operation of Sections 70, 71, 72 etc unlike Section 80IA(5) or Section 80IA(6) and therefore, by that ratio business losses / depreciation have been rightly set off by the Assessing Officer prior to computing deduction u/S. 10A of the Act? 4. Mr. Suresh Kumar, learned standing counsel, revenue very fairly submits that all the thr....

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....s 10A and 10B shall be of the undertaking located in specified zones or 100% Export Oriented Undertakings, as the case may be, and this shall not have any material relationship with the other business of the assessee outside these zones or units for the purposes of this provision." 17. If the specific provisions of the Act provide [first proviso to Sections 10A(1); 10A (1A) and 10A (4)] that the....