Transfer of technical manpower: allowed for SEZ software units for section 10AA deduction if within prescribed ceiling. The Circular clarifies that transfer or redeployment of existing technical manpower from an existing unit to a new SEZ unit in the first year of commencement will not be construed as splitting up or reconstruction of an existing business, provided the number of technical manpower so transferred does not exceed twenty percent of the total technical manpower actually engaged in developing software at any point of time in the given year in the new unit.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Transfer of technical manpower: allowed for SEZ software units for section 10AA deduction if within prescribed ceiling.
The Circular clarifies that transfer or redeployment of existing technical manpower from an existing unit to a new SEZ unit in the first year of commencement will not be construed as splitting up or reconstruction of an existing business, provided the number of technical manpower so transferred does not exceed twenty percent of the total technical manpower actually engaged in developing software at any point of time in the given year in the new unit.
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