articles or things or providing any services referred to in section 10AA of that Act, in a case where the letter of approval, required
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
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
facts in deleting the disallowance of claim
of deduction u/s.10AA ... account of the
deduction claimed under section 10AA of the Act
3. The facts in brief are that the assessee in the present case
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
facts in
denying the relief claimed by the Appellant under section 10AA of the Act of INR
303,16,58,824. The learned ACIT ... fact in denying the
relief claimed by the Appellant under section 10AA of the Act on the incremental
revenue pursuant to the Advance Pricing Arrangement
2017Yash Jewellery Pvt Ltd
2.1 Since the appellant enjoyed deduction under section 10AA and shifting of
profits is not possible, Transfer Pricing adjustment ... bank of Rs. 11,91,242/-
is eligible for deduction under section 10AA and accordingly, the same should
have been included in computing eligible profit
purpose) or clause (17) or clause (32), of section 10 or section 10AA or section 16 or clause (b) of section 24 (in respect
shall be computed,- (i) without any deduction under the provisions of section 10AA or clause (iia) of sub-section (1) of section 32 or section
that trading activities of the
assessee are eligible for exemption under section 10AA of
the Act?
(B) Whether the Appellate Tribunal has erred in holding ... shall increase the deduction under section
10AA by ignoring that the documentary evidences have not
been furnished and that assessee's eligibility under section