The assessee was engaged in the business of manufacturing and export of Bi-axially Oriented Polypropylene Films (‘BOPP’). The assessee had manufacturing units set up both in the Domestic Tariff Area (‘DTA’) as well as Special Economic Zones (‘SEZ’) The assessee was allowed deduction under section 10AA since assessment year 2014-15. In its return for assessment year 2017-18, the assessee reported certain income from its SEZ unit, under the head ‘profit and gains of business and profession’ (PGBP). The assessee first calculated the PGBP of the eligible unit separately by claiming the deduction under section 10AA in Form ITR-6. In other words, the losses of the ineligible unit i.e. the unit set up in the DTA, was not taken into account while calculating the PGBP of the eligible unit. AO set off  the entire loss of the ineligible unit got set off against the business profit of the eligible unit and thereupon the net loss of the ineligible unit to be carried forward was thus brought down to ‘Nil’. The assessee filed the writ petition. Allowing the petition the Court held that once it is abundantly clear that the amendment in section 10AA takes effect only from 1-4-2018 and would apply only from assessment year 2018-19, it is clear that for all the assessment years prior to 2018-19, the law explained by the Supreme Court in CIT v. Yokogawa India Ltd ( 2017) 391 ITR 274 (SC) would apply.  Accordingly, a direction is issued to the respondent to either accept the manual return of the assessee or alter the software to permit it to again file online its returns claiming the carry forward of losses of its ineligible unit for the assessment years in question.  (AY. 2017-18)