The assessee was a private limited company engaged in the business of manufacture and export of readymade garments. The assessee had three units, two of which were export oriented units, and showed profit and loss from all of them. The assessee had set off losses of the units against the profits of the unit making profits and offered the balance to tax under the head Income from business.  The Assessing Officer  held that losses of the export oriented units could not be allowed to set off against the profits of unit No. I. This was upheld by the Commissioner (Appeals) and the Tribunal. On appeal :allowing the appeal the Court held that   the assessee was entitled to set off the loss from export oriented unit against the income earned in the domestic tariff area unit in accordance with section 70 . Referred CBDT Circular dated July 16, 2013 ([2013] 356 ITR (St.) 7)  ( AY.2008-09)