mentioned in SEZ Act ) has been broadly incorporated into
the Income Tax Act . Section 51 of SEZ Act having an over riding
effect over ... other statutes. When the terms like
SEZ, authorized operations, developers etc have been specifically
defined under the SEZ Act , it is not open
mentioned in SEZ Act ) has been broadly incorporated into
the Income Tax Act . Section 51 of SEZ Act having an over riding
effect over ... other statutes. When the terms like
SEZ, authorized operations, developers etc have been specifically
defined under the SEZ Act , it is not open
mentioned in SEZ
Act ) has been broadly incorporated into the Income Tax Act .
Section 51 of SEZ Act having an over riding effect over ... other statutes. When the terms like SEZ,
authorized operations, developers etc have been specifically defined
under the SEZ Act , it is not open
SEZ Rule 2006 as well as section 51 of SEZ and submitted that
there is a reference of section 10AA in SEZ as it exists ... amendment has been made in the
SEZ. The learned AR has further submitted that the provisions of
SEZ Act has overriding effect on any other
assessee also referred to definition of manufacture as provided
under SEZ Act, 2005 and foreign trade policy, which are as under:
"Manufacture means ... word 'manufacture' as per sec.2(r) of the
SEZ Act, 2005 is as under:
"The manufacture means to make, produce, fabricate
certificates, the assessee has been notified as
co-developer under the SEZ Act . The Ld. AR further submitted that, as per
section ... SEZ Act, a co-developer is included within the definition of
developer. Hence, the Ld. AR contended that the benefit available to a
developer
Act. Subsequently, the case of the assessee
company was selected for scrutiny assessment under section 143(2) of
the Act.
3. During the course ... given a certificate under section 15(9) of the SEZ Act, 2005,
therefore, it was disentitled from claiming exemption under section 10AA
of the Act
recognized 100% Export Oriented
Undertaking (EoU) under the Industries (Development and
Regulation) Act, 1951 . He further observed that the AO
confronted the appellant and asked ... SEZ will
themselves be entitled to exemption under Sec. 10A on exports
and the legislature seems to have not incorporated the provision
of SEZ Act
proceedings u/s 143(3) of the Income Tax Act, 1961 (in short 'the
Act')
Heard both the parties. Case file perused ... business
u/s 37 of the Act.
5
ITA No. 1251/Hyd/2019 AY 2016-17
Kakinada SEZ Limited
We find force in assessee
Act.
10. Erred in confirming the disallowance of the claim of
assessee company u/ s 80 G of the Act amounting ... have appreciated the fact that profit from SEZ
unit is allowable u/ s 10AA of the Act.
11.b Ought to have appreciated that
