No set-off of business losses of non 10A units while computing deduction u/s 10A

Brief of the Case

ITAT Bangalore held In the case of DCIT vs. M/s. Makino India Pvt. Ltd. that the relief under Section 10A is in the nature of exemption even though termed as deduction. The profits from such 10A units are neither subject to the charge of income tax nor includible in total income. The question of setoff of losses of non 10A units either belongs to current year loss or earlier year losses does not arise at all. The Karnataka high Court held that the income eligible for deduction u

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