deduction of tax at
source.
Disallowance of deduction under section 10AA
4. That the DRP / assessing officer erred on facts and in law in
determining ... deduction allowable to the appellant under section
Page 4 of 95
10AA of the Act at Rs.11,40,34,006 only as against deduction
appeal the assessee has mainly challenged the disallowance of
deduction u/s 10AA amounting to Rs. 10,43,46,127/- relating to
profits derived ... erred in denying the deduction claimed by the
Appellant under section 10AA of the Act amounting to Rs.10,43,46,127
relating to profits
addition on account of restriction of
deduction on account of u/s 10AA to Rs. 42306994/- and addition on account of arms length ... economic Zones [in short SEZ]. The
assessee has claimed deduction u/s 10AA of the Act filing audit report in Form 56F. On
examination
claimed by the Appellant under section 10AA of
the Act, without appreciating the facts of the appellant case and
the relevant provisions ... erred in disallowing the deduction claimed by
the Appellant under section 10AA of the Act, on a factually
incorrect assumption that the services were provided
income after claiming
deduction of Rs.226,98,41,758/- under section 10AA of the IT Act. However, the
assessee has paid ... replies given by the assessee,
rejected the claim of deduction u/s 10AA of the Act made by the assessee in
respect of income from
upholding the reassessment order disallowing the
exemption u/s 10A and 10AA ... failed to appreciate that the deduction u/s 10A and 10AA of the Act
was allowed by the Ld. AO in the original assessment order
denying
deduction claimed by the Appellant under section 10AA of the Act;
6.1. On the facts and circumstances of the case ... erred in disregarding the fact that the
disallowance under section 10AA of the Act in the year of
formation has been deleted and thus
holding
that the appellant is fulfilling the criteria u/s 10AA which make it eligible
for deduction u/s 10AA , as claimed ... Noida are eligible for deduction u/s 10AA of the IT Act 1961 without
considering that agreement that nowhere in the agreement it is
mentioned
erred in upholding that while computing
deduction u/s 10AA of the Act following receipts are to be excluded within the
ambit of "export ... turnover" as defined in Explanation 1 (i) to section 10AA of the
Income Tax Act:
(a) Freight & Telecommunication expenses
erred in upholding that while computing
deduction u/s 10AA of the Act following receipts are to be excluded within the
ambit of "export ... turnover" as defined in Explanation 1 (i) to section 10AA of the
Income Tax Act:
(a) Freight & Telecommunication expenses
