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2015 (9) TMI 1539 - HC - Income TaxComputation of deduction u/s 10A - Whether Tribunal was justified holding that there was nothing on record to show that the profits arrived by the assessee in respect of the 10A unit carrying on the business of manufacturing of sewing machine needles was not in normal course of business and that the abnormally high profit was due to extraordinary arrangement between the assesee and the German Company entered into only with a view to boost the profits of the assessee and therefore, allowing deduction ? - Held that:- The question as proposed stands concluded against the Appellant Revenue by the decision of this Court for the Assessment Year 2004-05 [2012 (9) TMI 407 - BOMBAY HIGH COURT ] and AY 2005-06 [2015 (6) TMI 1044 - BOMBAY HIGH COURT] wherein held Section 10A is a provision which is in the nature of a deduction and not an exemption - the deduction under Section 10A has to be given effect to at the stage of computing the profits and gains of business - Section 80B(5) defines for the purposes of Chapter VI-A “gross total income” to mean the total income computed in accordance with the provisions of the Act, before making any deduction under the Chapter - Decided against revenue
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