assessee for deduction of Rs.56,25,38,852/- under section 10AA
of the Income tax Act on the ground that activities of the
assessee ... appeal relates
to the claim of assessee's deduction under Section 10AA of the Income Tax
Act. Both the parties agreed that this issue
income after claiming deduction
of `3,61,19,032/- under section 10AA of the Income Tax Act, 1961 (in short ... Section 51 of the SEZ Act and found that
trading done by the assessee is a service and, therefore, deduction
under Section 10AA is allowable
which
indicate contravention of the provision of the section 10AA(4)(iii) of
the Act".
11. The issue raised in ground ... u/s 1OAA. It is submitted that the
said queries are quite irrelevant with respect to the provisions of
section 1OAA as the section
observed that the assessee company had claimed a deduction under
Sec. 10AA of RS. 1,26,76,514/- in respect of profits of SEZ unit ... show cause as to why the deduction
under Sec. 10AA may not be added back to its total income, the
assessee submitted that by virtue
dated 30/10/2012 qua allowance of deduction u/s 10AA to the assessee.
2. Briefly stated, the assessee being resident firm engaged ... could not be more than 2%.
Finally, applying the provisions of Section 10AA(9) read with Section
80IA(10) the Ld. AO, in the alternative
2446/Mum/2014, A.Y.2009-10
12/12/2011 u/s u/s 143(3) by ITO Wd 13 (1)(4) Mumbai ... aside the assessment made u/s 143(3) by the Assessing
Officer allowing exemption u/s 10A / 10AA on the ground that Assessing Officer
exemption allowed in the
assessment order under Sec. 10A as well as under Sec. 10AA of the Act were
3 ITA No. 3719/Mum/2017 ... pointed out that the claim of exemption under Sec. 10A as well
as under Sec. 10AA of the Act was computed by excluding the
communication
Applicators of Paints and
Epoxy flooring. The Assessee raised the claim u/s 10AA(9) r.w.s.80-A(8)
in respect of Apportionment ... dispute on the
eligibility of SEZ unit for deduction under
section 10AA . There is no dispute on
the genuineness of the expenditure incurred.
The dispute
erred in directed the AO to grant deduction u/s 10AA of
the I.T. Act".
3. Brief facts of the case are that ... return of income for relevant AY on 25.09.2009 and
claimed deduction u/s 10AA of the Act. The assessment was completed
from the total turnover for the purpose of
computation of deduction u/s 10AA of the Act, as these are spent in
foreign currency ... u/s 143(2) and
142(1) were issued and served upon the assessee. During the year, the
assessee claimed deduction u/s 10AA
