ITO 2(3)(3), MUMBAI vs. ZENSAR TECHNOLOGIES LTD, MUMBAI
In the result, appeal by the assessee is allowed for statistical purpose
ITA 955/MUM/2013[2002-03]Status: DisposedITAT Mumbai14 Sept 2022AY 2002-03
Bench: Shri G.S. Pannuand Shri Sandeep Singh Karhail
For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Anil Kumar Das
Section 10ASection 115JSection 143(3)Section 250Section 263Section 80HSection 92C
…es from earlier year for the purpose of computing profits eligible for deduction u/s.80HHE of the Act. The ld. DR before us placed reliance on the decision of the Hon‟ble Madhya Pradesh High Court in the case of Vippy Solvex Products Ltd., vs. CIT reported in 273 ITR 107 and also on the decision of the Hon‟ble Supreme Court in the case of Ipca Laboratories vs. DCIT reported in 266 ITR 521, in support of the contentions of the ld. CIT. We find there are two stages of computation of deduction u/s.80HHE of the Act. The first stage is the profits eligible for deduction u/s.80HHE has to be computed in the following fo…