defined in Section 2(j) of the Special Economic Zones Act, 2005. The
Petitioner has been allowed deduction under Section 10AA of the Income ... eligible unit') is eligible to claim
deduction under Section 10AA. Following the decision of the Supreme
Court of India in CIT v. Yokogawa India
scope of the main section and it
cannot override what the main Section provides. Therefore, the Explanation
inserted to Section 10AA(1) of the Income ... main Section but cannot change the substantive provisions of the main Section
under the Act. The Explanation inserted in Section 10AA(1) of the Income
section (3) of Section 92C
are attracted. It follows that sub-section (4) of Section 92C is not
attracted.
25. More importantly, the proviso ... section (4) of Section
92C also clearly states that no deduction under Section 10A or
10AA or 10B or under Chapter
section (3) of Section 92C
are attracted. It follows that sub-section (4) of Section 92C is not
attracted.
25. More importantly, the proviso ... section (4) of Section
92C also clearly states that no deduction under Section 10A or
10AA or 10B or under Chapter
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
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 ... treated as "manufacturing" as per Section 2(r) of the SEZ Act
read with Section 10AA of the IT Act and accordingly
account of
50% disallowance of deduction under Section 10AA of
the Act, being excess claimed by the assessee and
assessed the total income ... Assessing Officer making disallowance
of Rs. 7,64,15,421/= under Section 10AA of the Act, the
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HC-NIC Page
profit from the eligible
business. This would attract section 80IA(10) read
with section 10AA(9) of the Act.
9. With this background, we have ... could have questioned the assessee within the purview
of section 80IA(10) read with section
10AA(9) of the Act. This would be relevant since
issue concerning the claim of the respondent/assessee
for deduction under Section 10AA of the Income Tax Act, 1961 [in
short ... before adjusting deduction claimed under Section 10AA of the 1961 Act,
amounting to Rs.14,81,52,422/-. The respondent/assessee, thus, pegged its
Signature
excluded from export turnover for the purpose
of computing deduction under Section 10AA of the
Income Tax Act, 1961, when the same is against ... export turnover for the
purpose of computation of deduction under Section 10AA
of the Income Tax Act, 1961 vitiated by perversity and
arbitrariness
