appeal,
Held "that the provisions of Section 10A and Section 10AA later introduced serve the
very same purpose of granting exemption on the profits ... free trade zones, will continue to enjoy tax exemption under
section 10A and section 10AA respectively. The still worse position is that the
appellant would
framed u/s
143(3) of the Act at a total income of ₹60,90,498/- after disallowing the
deduction u/s. 10AA ... eligible.
It is because as per the provision of Section 10AA of the Act the assessee
should be engaged in the manufacturing / producing articles
claim in his return of income for any deduction under section
10A or section 10AA or section 10B or section 10BA or under any provision ... gains shall not be allowed under any
provisions of section 10A or section 10AA or section 10B or section 10BA or
under any provisions
framed u/s 143(3) of the Act at a total income of ₹60,90,498/-
after disallowing the deduction u/s. 10AA ... trading activity is not eligible because as per the provision of Section 10AA of the Act the
assessee should be engaged in the manufacture/production
only ground is against the allowing of the benefit under section
10AA of the Income-tax Act, 1961(hereinafter referred ... activity in the SEZ, the AO opined that the
benefit of section 10AA of the Act was not permissible. The assessee
contended that there
Section 10AA
after Section 10A of the Act and Clause (iii) of Explanation 1 below sub-section (9) of Section
10AA contains the definition ... prefaced by words "for the purpose of this section" i. e. section 10AA of the Act, but it
dispels the ambiguity, uncertainty
manufacture' as defined vide section 2(r) of the SEZ Act is
incorporated in section 10AA ... section do
not apply to other section in Chapter III. He referred to explanation (4) to section 10A and
explanation (1) to section 10AA
zones, would continue to enjoy tax
exemption under section 10A of the Act and section 10AA of the Act respectively. The assessee
was allowed exemption ... free trade zones, will continue to enjoy
tax exemption under section 10A and section 10AA respectively. The still worse position is
that the appellant would
zones, would
continue to enjoy tax exemption under section 10A of the Act and section 10AA of
the Act respectively. The assessee was allowed exemption ... free trade
zones, will continue to enjoy tax exemption under section 10A and section 10AA
respectively. The still worse position is that the appellant would
special economic zone under section 10A and units in the free trade zone
provided under section 10AA and the exemption available to 100 per cent ... free trade zones, will continue
to enjoy tax exemption under section 10A and section 10AA respectively. The still worse
position is that the appellant would
