Deduction under section 10A/10AA: transfer of technical manpower to new SEZ unit allowed if within prescribed limits. Clarification prescribes that transfer or re-deployment of technical manpower into a new SEZ unit will not amount to splitting up or reconstruction for claiming deduction under sections 10A/10AA if transfers do not exceed a prescribed proportion of the SEZ unit's technical workforce at year-end, or alternatively if the assessee can demonstrate equivalent net additions of technical manpower across its units; the assessee may elect either route and the circular applies only to software and IT-enabled service SEZ units and is not retrospective.
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Provisions expressly mentioned in the judgment/order text.
Deduction under section 10A/10AA: transfer of technical manpower to new SEZ unit allowed if within prescribed limits.
Clarification prescribes that transfer or re-deployment of technical manpower into a new SEZ unit will not amount to splitting up or reconstruction for claiming deduction under sections 10A/10AA if transfers do not exceed a prescribed proportion of the SEZ unit's technical workforce at year-end, or alternatively if the assessee can demonstrate equivalent net additions of technical manpower across its units; the assessee may elect either route and the circular applies only to software and IT-enabled service SEZ units and is not retrospective.
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