2016 (9) TMI 509

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..... s aspect is not considered and brushed aside by merely saying that the Tribunal has held it to be a 'service' and that it is a question of fact. No doubt, insofar as activity carried on by the respondent-assessee is concerned, factual aspects are not in dispute. However, whether that would constitute 'service' within the meaning of Section 10AA of the Act would be a question of law and not a quest .....

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..... he SEZ unit of the respondent-assessee is to be considered as 'service' eligible for exemption under Section 10AA of the Income Tax Act, 1961 (hereinafter referred to as 'Act'). It was the submission of the appellant that for this purpose, the Income Tax Appellate Tribunal could not have relied upon the definition of 'services' as per SEZ Rules when there is no such provisi .....

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