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2014 (5) TMI 1127 - AT - Income TaxClaiming the deduction u/s. 80IA(4)(iv)(a) - Held that:- We find that the issue stands squarely covered in favour of the assessee by the decision of Velayudhaswamy Spinning Mills (P) Ltd. Vs. ACIT [2010 (3) TMI 860 - MADRAS HIGH COURT] and f Serum International Ltd. Vs. Addl. CIT, Range-6 [2013 (1) TMI 688 - ITAT PUNE ] wherein held profits are to be computed as if such eligible business is the only source of income of the assessee. When the assessee exercises the option, only the losses of the years beginning from the initial A.Y. are to be brought forward and not the losses of the earlier years which have been already set off against the income of the assessee - no notional brought forward and set off against the profits of the eligible business as no such mandate is provided in section 80-IA(5). When the assessee exercises the option, only the losses of the years beginning from the initial A.Y. are to be brought forward and not the losses of the earlier years which have been already set off against the income of the assessee.- Decided in favour of assessee.
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