PCIT v. Infosys BPO Ltd. (2021) 277 Taxman 320 (Karn.)(HC)

S. 70 : Set off loss-One source against income from another source-Same head of income-Loss from for eligible for exemption could be set off other unit which was not eligible for exemption under same head of income.

Dismissing the appeal of the revenue the Court held that loss sustained by assessee company from its unit which was eligible for exemption under section 10A could be set-off against profit of its other unit which was not eligible for exemption under said section under same head of income.  (AY. 2006-07)