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2019 (8) TMI 1195 - AT - Income TaxComputation of deduction u/s 10A - non-allowance of carry forward losses - HELD THAT:- Respectfully following the aforesaid decision of the Hon’ble Apex Courts in the case of CIT Vs. Yokogawa India Ltd. [2016 (12) TMI 881 - SUPREME COURT] wherein the settled position in law is laid out, we also hold that the losses and unabsorbed depreciation of the Non-STPI Units shall not be adjusted against the profits of the STPI Unit for the purposes of computation of the deduction u/s 10A to be allowed to the assessee. Deduction u/s 10A – treatment of enhanced Assessed income - HELD THAT:- additions / disallowances have led to enhancement of the taxable business income of the assessee and consequently the assessee is entitled for deduction u/s 10A on such enhanced income. Therefore, respectfully following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. M. Pact Technology Services Pvt. Ltd., [2018 (8) TMI 202 - KARNATAKA HIGH COURT] we hold that the deduction u/s 10A shall be allowed on the assessed income. The AO is accordingly directed. Deduction u/s 10A – Expenses to be reduced from both Export Turnover and Total Turnover - HELD THAT:- Respectfully following the decision of the Hon'ble Apex Court in the case of CIT Vs. HCL Technologies L td. [2018 (5) TMI 357 - SUPREME COURT], we direct the AO to allow assessee' s claim for deduction u/s 10A. Consequently, the grounds raised by revenue are dismissed.
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