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TMI Blog2019 (9) TMI 1261X X X X Extracts X X X X X X X X Extracts X X X X ..... in ITA No.4637/Mum/2015 for A.Y.2011-12 arises out of the order by the ld. Commissioner of Income Tax (Appeals)-17, Mumbai in appeal No.CIT(A)-17/IT-15/14-15 dated 15/05/2015 (ld. CIT(A) in short) against the order of assessment passed u/s.143(3)of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 04/02/2014 by the ld. Income Tax Officer-8(2)(4), Mumbai (hereinafter referred to as l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncy services - Rs. 9,38,261/- US Office support services - Rs. 1,04,62,522/- Other Expenses - Rs. 19,581/- ----------------------- Total - Rs. 1,38,44,752/- The ld AO reduced the aforesaid expenditure incurred in foreign currency for providing technical services outside India from the Export Turnover while computing the deduction u/s 10AA of the Act and accordingly determin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The next ground to be decided in this appeal is as to whether the ld CITA was justified in directing the ld AO to allow the carry forward of losses without setting it off against the income eligible for deduction u/s 10AA of the Act. 6. We have heard the ld DR. We find that the ld CITA had placed reliance on the order passed by his predecessor for Asst Year 2010-11 in assessee's own case in Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ase of non-STPI unit or in the case of very same undertaking. Following the said decision, the ld CITA for the year under consideration directed the ld AO to allow the carried forward of losses without setting it off against the income exigible for deduction u/s 10A of the Act. We find that similar views were endorsed by the Hon'ble Supreme Court in the case of PCIT vs Rangsons Electronics Pvt Ltd ..... X X X X Extracts X X X X X X X X Extracts X X X X
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