2012 (5) TMI 701

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... passed u/s 263 for the assessment year 2005-06. 2. The CIT observed that assessment was completed vide order dated 29/12/2008 u/s 143(3) of the Act, for the AY 2005-06 was erroneous as well as prejudicial to the interests of the revenue, therefore, a show cause notice was issued vide letter dated 22/09/2010 pointing out that the AO wrongly allowed deduction u/s 10A without setting off of loss .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ould be removed at the source itself and not after computing the Total income. Hence the income eligible for exemption u/s 10A would not enter into computation as the same has to be deducted at the source level. Therefore the loss of a non 10A unit cannot be set off against the income of the 10A unit. 5. The Special bench of the Chennai Tribunal has come to the same conclusion in the case of Sc .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X