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2009 (8) TMI 676 - HC - Income TaxManufacture - the assessee claimed deduction of export profit in respect of the blended tea exported from the industrial unit under Section 10A of the Income Tax Act. However, the assessing authority held that "blending" does not answer the description of manufacture or processing and so much so, assessee is not entitled to deduction of export profits claimed under Section 10A of the Act. It is the specific case of the department that blending can be treated as a manufacturing activity only after the definition clause of "manufacture" contained in Section 2(r) of the Special Economic Zones Act, 2005 is incorporated in the provisions of Section 10AA of the Income Tax Act with effect from 10-2-2006. submission that benefit of exemption u/s 10A eligible even before said date applying definition of 'manufacture' as contained in EXIM Policy 2002-07. Held that - EXIM Policy definition applicable. Later amendment to section 10aA of Income Tax Act, 1961 only clarificatory and definition applies to section 10A also. Deduction of export profit allowed.
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