Zone,
company claimed deduction of Rs. 6832,18,56,826/- u/s 10AA of the IT. Act, as
per Form 56F(Revised) submitted ... appellant on its export turnover.
Section 10AA of the Act allows to a unit, deduction of profits and gains derived
from the export of article
undertakings". Accordingly, it claimed
deductions u/s 10A/10AA of the Act in respect of profits earned by
profit making SEZ/STPI undertakings ... took the view that the provisions of section
10A/10AA of the Act are a special code by themselves. Accordingly
he took the view that
assessment
year 2010-11, for the purposes of computing deduction u/s. 10AA , the AO
excluded the expenditure incurred in foreign currency on communication ... income from
business for the purpose of computation of deduction u/s. 10AA. The AO
excluded them. The assessee , out of the advance paid
seeking
foreign tax credit in respect of income pertaining to Section 10A / 10AA
eligible units in India. The ground No.8 raised by the Revenue ... claimed foreign tax credit in respect of income pertaining to section
10A / 10AA of the Act eligible units in India.
27. Brief facts
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
Asst Cit (Ltu) 2, Mumbai vs Reliance Industries Ltd, Mumbai on 28 September, 2018
IN
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
erred in allowing deduction u/s 10AA before
computing the brought forward business losses and unabsorbed
depreciation without appreciating that after the amendment ... erred in allowing deduction u/s 10AA before
computing the brought forward business losses and unabsorbed
depreciation ignoring that the Hon'ble Karnataka High
raised in assessee‟s appeal
is regarding deduction under section 10AA of the Act in respect of SEZ
units of the assessee which commenced ... emanating from
the record are: The assessee had claimed deduction under section 10AA of
24
Tata Consultancy Services Ltd.
ITA No. 17/Mum./2011
erred in denying the
benefit of deduction under section 10AA of the Income tax Act to the
Assessee.
4. Without prejudice to the above ... deduction to the tune of Rs. 47,19,678/- u/s.10AA of the
1961 Act by both the authorities below. The assessee
