Court held that losses of unit eligible for deduction were already set-off against other business income such losses could not be again carried forward and set-off against eligible profits of same unit in subsequent year. Followed CIT v. Yokogawa India Ltd. (2017)391 ITR 274 (SC). Computer software sales made to STP/SEZ units would not be excluded from export turnover for computing deduction under section 10A/10A. Followed Wipro Ltd. v. Dy. CIT (2016) 382 ITR 179 (Karn.)(HC). VAT/GST would not be excluded from export turnover and total turnover for computing deduction under section 10A/10AA. Followed Wipro Ltd. v. Dy. (2016) 382 ITR 179 (Karn.)(HC). Tribunal could not exclude 80 per cent of uplinking charges from turnover when such exclusion was already limited to 5 per cent of telecommunication charges while computing deduction under section 10A. Followed CIT v. TATA Elxsi Ltd. (2016) 382 ITR 654 (Karn.) and CIT v. HCL Technologies Ltd. (2018) 404 ITR 719. (SC (AY. 2006-07)
Wipro Ltd. v. Addl. CIT (2021) 279 Taxman 203 (Karn.)(HC)
S. 10A : Free trade zone-losses of unit eligible for deduction were already set-off against other business income-Such losses could not be again carried forward and set-off against eligible profits of same unit in subsequent year-Computer software sales made to STP/SEZ units would not be excluded from export turnover for computing deduction under section 10A/10AA-VAT/GST would not be excluded from export turnover and total turnover for computing deduction under section 10A/10AA. Tribunal could not exclude 80 per cent of uplinking charges from turnover when such exclusion was already limited to 5 per cent of telecommunication charges while computing deduction under section 10A. [S. 10AA]