granting additional
deduction of Rs. 18,71,030 under section 10AA of the Act claimed by the Appellant during the course
of assessment proceedings ... that provision of sub-
section (5) and (6) of section 10A shall apply by virtue of the provision of section 10AA
impugned order as well as the processing of the return
by the CPC u/s 143(1) of the I.T. Act, 1961. It is contended ... gains for further 5 A.Ys and thereafter. Thus, sub-
section (1) of section 10AA of the Act has specified the profit and
gain derived
provisions of sub-sections (5) & (6) of section 10A of
the LT. Act shall apply to the exemption u/s 10AA ... deduction shall be allowed under section
80HH or section 80HHA or section 80-1 or
section 80- IA or section 80-IB in relation
date provided under Section 139(1) of the Act, is not mandatory
for claiming deduction under Section 10AA of the Income ... claim deduction under Section 10B of the Act. However,
there is no such provision in Section 10AA
decision pertained to section 10A / 10B of the
Act, the assessee reasonably believed that the same principle
extends to section 10AA of the Act, which ... belief that
the principle applicable to sections 10A / 10B of the Act would also
apply to section 10AA of the Act. The assessee has also
mentioned in the assessment order under sec.10A is a
typographical mistake. It should be under sec. 10AA . The assessee is
100% EOU located ... mentioned in the
assessment order under sec.10A is a typographical mistake. It should
be under section 10AA . The assessee is 100% EOU located
section 10B of the Act, whereas in the
revised return filed under section 139(5) of the Act,
assessee did not claim deduction under section ... return under section 139(1) was a mandatory
condition not directory. However, notably, there is no such
equivalent/similar provision in section 10AA
section 10B of the Act, whereas in the
revised return filed under section 139(5) of the Act,
assessee did not claim deduction under section ... return under section 139(1) was a mandatory
condition not directory. However, notably, there is no such
equivalent/similar provision in section 10AA
further erred in
not allowing consequential deduction under section
10AA of the Act on the "Profits and Gains from Business
or Profession" derived ... ground no.5 of assessee's appeal is deduction
u/ sec.10AA of the Income Tax Act, 1961.
27. CA, Sriram Seshadri, Learned Counsel
intimation under section 143(1)(a) of the Act, dated
30/03/2019, the CPC did not allow the claim under section 10AA ... order under section 154 of the Act allowing the deduction
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ITA-TP No. 78/Hyd/2022
under section 10AA
