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2015 (10) TMI 2110 - AT - Income TaxEntitlement to eduction U/s. 10B on the unit established in SEZ - manufacture - in earlier years, the deduction claimed U/s. 10B was not allowed - disallowance of 25% of expenditure on earth development expenses taking into account the non-verifiable nature of the expenditure. - Held that:- Explanation 4 of section 10B makes it clear that the term ‘manufacture and produce’ as contemplated under section 10B is inclusive and not exhaustive. Therefore, considering the facts of the assessee’s case in the context of provision contained u/s 10B as well as in the light of ratio laid down by the Hon’ble Supreme Court in the case of Sesa Goa Ltd. (2004 (11) TMI 14 - SUPREME Court) and Instruction issued by the CBDT, we are of the opinion that the CIT(A) was correct in allowing the claim of deduction u/s 10B of the Act. - Decided in favour of assessee.
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