Wednesday, 19 March 2014

Few Points on Section 10 of Income Tax



Ø  The following judgements where it held that losses of STPI Units is required to be adjusted with profit made by other units,

(a)  The ITAT Mumbai in the case of Capegemini India (P) Limited IT Appeal No. 7729/MUM./2010 held that “As per provisions of section 10A in force prior to assessment year 2001-02, the profit and gain from the eligible undertaking was not to be included in the total income which meant that the income from the eligible unit was exempt from tax. However, provisions were amended with effect from assessment year 2001-02 and as per the amended
provisions, the profit and gain derived by and eligible undertaking is required to be deducted from the total income. Thus, from assessment year 2001-02, section 10A is no longer an exemption provision and it allows only deduction from total income. The deduction was to be allowed in respect of each eligible undertaking separately which had also been clarified by the CBDT. Prior to assessment year 2001-02 when section 10A was an exemption provision, section 10(6) provided restriction on set off and carried forward of business loss and unabsorbed depreciation. However, subsequently, section 10(6) was amended by Finance Act, 2003 with effect from assessment year 2001-02 and such restriction was withdrawn which was consistent with the new scheme of section 10A which was a deduction provision and not exemption provision from assessment year 2001-02. Therefore, the loss from 10A unit had to be adjusted against taxable profits of other units after deduction under section 10A had been allowed in respect of each eligible unit. Therefore, the order of the Additional Commissioner could not be sustained. Accordingly, the order of the Additional Commissioner was to be set aside and claim of the assessee was to be allowed. 

(b)  Again, In the case of Yokogawa India Limited , Appeal No. 853, the Bangalore ITAT held that “Assessee-company was engaged in industrial automation and information technology - It had three divisions - One of assessee's division, i.e., software division was registered with STPI - Said division was making profits - However, other two divisions had been incurring a loss for a long time - Whether following decision of Special Bench in case of Scientific Atlanta India Technology (P.) Ltd. v. Asstt. CIT [2010] 38 SOT 252 (Chennai), it was to be held that assessee was entitled to deduction under section 10A in respect of software division without setting off of brought forward loss and unabsorbed depreciation of other two units - Held, yes

(c)  In the very recent judgment of Karnataka High Court , the  High Court held the following : 
“As the income of 10-A unit has to be excluded at source itself before arriving at the gross total income, the loss of non 10-A unit cannot be set off against the income of 10-A unit under section 72. The loss incurred by the assessee under the head profits and gains of business & Profession had to be set off against the profits and gains if any, of any business or profession carried on by such assessee. Therefore, as the profits and gains under section 10-A is not to be included in the income of the assessee at all, the question of setting off the loss of the assesseee of any profits and gains of business against such profits and gains of the undertaking would noty arise. Similarly, as per section 72(2)_, unabsorbed business loss is to be first set off and thereafter unabsorbed depreciation treated as current years depreciation under section 32(2) id to be set off. As deduction under section 10-A had to be excluded fro  the total income of the assessee, the question of unabsorbed business loss being set off against such profits and gains of the undertaking would not arise. In that view of the matter, the approach of the AO was quite contrary to the aforesaid statutory provisions and the appellate Commissioner as well as Tribunal were fully justified in setting aside the said assessment order and granting the benefit of section 10-A to the assessee


No comments:

Can GST Under RCM Not Charged and Paid from FY 2017-18 to October 2024 be Settled in FY 2024-25?

 In a recent and significant update to GST regulations, registered persons in India can now clear unpaid Reverse Charge Mechanism (RCM) liab...