No Set-off of losses or unabsorbed Depreciation/business loss against Profit Exempt U/s. 10A

Undisputedly, this is settled principle of law that even after amendment to Section 10A by the Finance Act 2000 w.e.f. 01.04.2001, Section 10A continues to be an exemption provision, though it is termed as provision providing deduction. Hon’ble Jurisdictional High Court in the judgement cited as 2012, 210 Taxman 237 (Del.) CIT Vs TEI Technologies (P) Ltd. held that Section 10A as it stands though decided as deduction provision is essential and in substances exemption provision. In order to decide the moot point that ‘as to whether the deduction u/s 10A of the Act with respect to it derived...