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2011 (9) TMI 276 - HC - Income Tax100% EOU - Exemption u/s 10B - Export profit - set off of unabsorbed depreciation carried forward from earlier years as provided under section 32(2) - Revision u/s 263 - Held that:- Section 10B(6) does not deal with computation of business profit during the period the assessee enjoys exemption under Section 10B(4) of the Act. On the other hand this sub-section is only an embargo against the assessee claiming any carried forward benefit under the sections referred to therein in the assessment for the assessment year following the end of the tax holiday enjoyed by the assessee under Section 10B(4) of the Act. - carried forward depreciation should be set off in the computation of business profit even during the period assessee enjoys exemption under Section 10B(4) of the Act. - Decision in CIT v. Himatasingike Seide Ltd. (2006 (8) TMI 125 - KARNATAKA High Court) followed - Decided in favor of revenue.
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