must export
articles or things or computer software.
Secondly, the said export may be done directly
by him or through other exporter after fulfilling ... Export
Turnover' in both these provisions does not
make any such distinction between the 'Direct
Export' and 'Deemed Export
chapter 6 & 8 of export import
policy as export and as receipt of foreign exchange. Therefore, deemed export sales made
to other ... directly attributable to such export.
(2) The such export oriented unit through whom the assessee has made export as
deemed export has also not claimed
export entitlements, including recognition as Status
Holder would accrue to exporter in whose name foreign
exchange earnings are realized. However, such export
shall be counted ... must export
articles or things or computer software. Secondly, the said
export may be done directly by him or through other exporter
after fulfilling
made
to their parties as well other export
oriented units are deemed exports under
EXIM policy and should also be treated as
export under Section ... assessment years, the
appellant has been denied deduction in respect of deemed
exports through third party and inter unit transfers.
9. Learned Senior counsel
export entitlements, including
12
recognition as status Holder would accrue to
exporter in whose name foreign exchange
earnings are realized. However, such export
shall ... export, as
clause 6.19 specifically provides for export to status
holder. Thus, in order to be eligible for exemption from
Income Tax, the exports should
allowed the plea of the Assessee as regards 'deemed export drawback', Mr.
Manchanda stated that the Revenue ought to have challenged the above ... even while accepted the Assessee's case as regards 'deemed export
drawback'.
17. The contention of the Assessee as regards customer claims
allowed the plea of the Assessee as regards 'deemed export
drawback', Mr. Manchanda stated that the Revenue ought to
have challenged the above ... even while
accepted the Assessee's case as regards 'deemed export
drawback'.
17. The contention of the Assessee as regards customer claims
Explanation 2(iii) to Section 10B
"export turnover" means the
consideration in respect of export by the
undertaking of articles or things ... Section 10AA read as
under:
"export turnover" means the consideration in
respect of export by the undertaking, being
the Unit of articles
amend or alter the above grounds as may be
deemed necessary.
2. The sole issue raised by the Revenue in this appeal is that learned ... GIDC, Makarpura, Vadodara, Gujarat. The
assessee is a 100% Export Oriented Unit approved by the Development
commissioner, Kandla Special Economic Zone, Gandhidham, Ministry of Commerce
Pr Commissioner Of Income Tax - Iii vs M/S Wipro Limited on 30 November, 2020
