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2011 (12) TMI 115 - DELHI HIGH COURTDeduction u/s 80HHC – setting off of aggregate brought forward losses of amalgamating company from both export and non-export activities in determining “profit of the business” for computing deduction – Held that:- Section 80AB makes it clear that the computation of income has to be in accordance with the provisions of the Act. Not only profits but also losses have to be taken into consideration. Expression “profit” occurring in Section 80HHC means a positive profit. To arrive at a net figure of positive profits, losses from export as well as non-export activities are to be taken into consideration. See IPCA Laboratories Ltd Vs. DCIT (2004 - TMI - 6141 - Supreme court). Decided against the assessee.
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