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2015 (6) TMI 165 - AT - Income TaxDeduction U/s 10AA - CIT(A) allowed claim - Held that:- The word services as mentioned in Section 10AA cannot be construed inconsistently with the definition of services given in the SEZ Act. Under the SEZ act, the trading is included in the services provided the trading is export of imported goods. We therefore, feel that the assessee is entitled to deduction u/s 10AA of the Act and therefore, the ld. CIT(A) was justified in allowing the exemption. - Decided against revenue. Addition of remuneration of Director - apportionment of salary among the taxable and non-taxable unit - Held that:- The company is running various units, which includes head office in jaipur, Mumbai and SEz Unit at Surat. The overall work either trading or manufacturing is responsibility of the Directors when company deals in precious items cannot depend upon only employees and managers. They take the decision what type of rough diamond should be imported, how it should be processed and re-exported. They not only take the business decision but also involve in the manufacturing proceeding which they performed at Surat. Therefore, we find that apportionment of salary among the taxable and non-taxable unit is rightly done by the ld Assessing Officer and confirmed by the ld CIT(A). Accordingly, we uphold the order of the ld CIT(A). - Decided against assesse.
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