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
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
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
after claiming
exemption of Rs.14,48,36,551/- u/s 10AA of the Income-tax Act, 1961
[hereinafter referred ... While doing so, the AO had
denied the exemption claimed u/s 10AA of the Act and made addition
Thereafter, the return was revised twice. The assessee claimed
deduction u/s.10AA . The assessment was completed by
determining the total income, under the regular ... further
noticed that the assessee company claimed deduction u/s.10AA in
respect of the eligible units. Turnover of these eligible units
short "the Act") after claiming deduction under section
10A / 10AA of the Act. Further, the assessee also declared book
profit ... claimed foreign tax credit in respect of
income pertaining to section 10A / 10AA of the Act eligible units in
India.
27. Brief facts
accepting the
contention of assessee to recomputed the deduction u/s 10AA after
considering the trading addition of Rs. 2,80,500/- ignoring the CBDT ... started commercial production from 21.04.2008
and has claimed deduction u/s 10AA of the Act. The assessee originally filed its
return of income
carried forward - Ground 3 (3.1)
Disallowance of claim of deduction under section 10AA in respect of interest
income - Grounds 4 (4.1 & 4.2)
Foreign ... Allowing foreign tax credit in respect of income pertaining to section 10A/10AA
eligible units in India - Ground 8
Restricting the TP adjustment made
same.
B. Corporate Tax
7. Disallowance of deduction claimed under section 10AA of the Act --
Chennai SEZ unit ... erred in denying the deduction under Section 10AA of the
Act amounting to Rs.181,403,235 claimed by the Appellant, by relying
following grounds
of appeal:-
1. In respect of deduction u/s 10A / 10AA in respect of certain eligible
undertakings of the Company ... allowing deduction u/s 10A / 10AA of Rs.240,14,52,340 in
respect of various eligible undertakings established after
