ACIT v. Geometric Software Solutions Co. Ltd. (2022) 196 ITD 466 (Mum.)(Trib.)

S. 10A : Free trade zone-Eligible undertaking-Gross total income-After amendment of section 10A by Finance Act 2000, said section became a provision for deduction but stage of deduction would be while computing gross total income of eligible undertaking under Chapter IV of Act and not at stage of computation of total income under Chapter VI of Act.

Assessee-company is engaged in software development and claimed deduction under section 10A for its two units situated in software technologies park. Assessing Officer reduced losses of one unit against eligible profits of other unit for computing deduction under section 10A. Held that after amendment of section 10A by Finance Act 2000, said section became a provision for deduction but stage of deduction would be while computing gross total income of eligible undertaking under Chapter IV of Act and not at stage of computation of total income under Chapter VI of Act.  (AY. 2005-06)