provisions:-
―80A(4) Notwithstanding anything to the contrary contained in section
10A or section 10AA or section 10B or section 10BA or in any provisions ... case may be. Even if Section 10A / Section 10B are construed as
exemption provisions, sub-section (4) of Section 80A cannot defeat such
construction
raised in assessee‟s appeal
is regarding deduction under section 10AA of the Act in respect of SEZ
units of the assessee which commenced ... before the 1st Day of April 2021. Sub-section (4) of section 10AA of the Act
lays down certain conditions upon fulfillment of which
territory of India, although procured by UNICEF, therefore, the
section u/s 10AA of the Income-tax Act, 1961 is not applicable in
the case ... authority u/s 35(2AB) is not a bar for
allowance of claim within the ambit of provision of section
35(1)(iv) or
denying
deduction claimed by the Appellant under section 10AA of the Act;
6.1. On the facts and circumstances of the case ... erred in disregarding the fact that the
disallowance under section 10AA of the Act in the year of
formation has been deleted and thus
ready reference relevant portion of section
10AA is reproduced below:
10AA. (1) Subject to the provisions of this section, in computing the total income ... countries in view of provisions of section 2(z) of SEZ
Act, 2005 r/w Section 27 and section
should be allowed.
Adjustment under section 92C(4)
2 .6 As per the learned AO deduction under section 10AA
was not permissible ... section 92C(4)
of the Act. The first proviso to section 92C(4) states that no
deduction under section 10A or section 10AA or section
losses andset-off of losses, thereby restricting
the deduction under section 10AA of the Act, following CBDT Circular
No.7 of 2013 dated 16 July ... judis
licenses.
(10.4) Deduction claimed under section 10AA of the Act by the
Gurgaon MrX SEZ unit amounting to INR 476,46,271 is sought
loss referred to in sub-section (1) of section 72 or sub-
section (1) or sub-section (3) of section ... deduction shall be allowed under section
80HH or section 80HHA or section 80-I or section 80-
IA or section 80-IB in relation
initiated proceeding u/s 263 of the Act to disallow the claim of assessee
of Rs. 5,93,30,777/- u/s. 10AA ... along with Audit report in order to claim deduction under section
10AA of the Act for A.Y. 2013-14. The assessee submitted form
obtain the form 56F which was
issued mentioning section 10A in place of section 10AA of the Income Tax Act. The
said inadvertent error ... u/s 10A of the Act. The assesse with mala fide
intention claimed the deduction u/s 10A as the provisions of section 10AA
