High Court held that assessee was allowed to set-off losses of its STP/SEZ unit against income of non-STP units of assessee. Followed CIT v. Yokogowa India Ltd (2017) 391 ITR 274 (SC). Held that deemed export, reimbursement of expenses, expenses incurred in foreign currency, delayed export proceeds and VAT/GST would form part of export turnover for purpose of computation of deduction under section 10A. Held that expenses of corporate office were to be allowed on ad hoc percentage of 20 percent and not based on turnover of various undertakings for purpose of deductions under section 10A. (AY. 2006-07)
CIT v. Wipro Ltd. (2022) 134 taxmann.com 301 (Karn.)(HC) Editorial : SLP of revenue dismissed; CIT v. Wipro Ltd. (2022) 285 Taxman 274 (SC)
S. 10A : Free trade zone-Set-off losses of STP/SEZ unit against income of non-STP units-Allowed to be set off-Export turnover-Deemed export, reimbursement of expenses, expenses incurred in foreign currency, delayed export proceeds and VAT/GST would form part of export turnover-Corporate office expenses-Allowed on ad hoc percentage of 20 percent and not based on turnover of various undertakings for purpose of deductions under section 10A.[S. 80IB, 80IC]