Setoff of unabsorbed depreciation available against income from other source

Hewitt Associates (India) Private Limited Vs ACIT (ITAT Delhi) Setoff of unabsorbed depreciation should be allowed against income from other source. Facts- The assessee, Hewitt Associates (India) Private Limited, engaged in providing support services to its associated enterprises (“AEs”). The services are software development support services and Business Process Outsourcing (BPO) services. The assessee had entered into international transactions with its AEs in respect of provision of software development services and BPO/ITeS with its AEs. TPO proposed an adjustment of Rs. 22,11,60,596/-...