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2015 (6) TMI 1044 - BOMBAY HIGH COURT

2015 (6) TMI 1044 - BOMBAY HIGH COURT - [2016] 384 ITR 140 - Computation of deduction u/s 10A - Tribunal came to the conclusion that there was nothing on record to show that the profits arrived at by the assessee in respect of the section 10A unit carrying on the business of manufacturing industrial sewing machine needles was not in the normal course of its business and that the abnormally high profit was due to extraordinary arrangement between the assessee and the German company entered into o .....

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ecision of this court in CIT v. Schmetz India P. Ltd. [2012 (9) TMI 407 - 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 .....

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ate Tribunal (the Tribunal) for the assessment year 2005-06. 2. Ms. Bharucha, learned counsel appearing for the Revenue urges the following questions of law for our consideration : "(a) Whether on the facts and circumstances of the case and in law the Tribunal was justified in coming to the conclusion that there was nothing on record to show that the profits arrived at by the assessee in respect of the section 10A unit carrying on the business of manufacturing industrial sewing machine need .....

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