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ITAT directed that deduction under s.10AA be computed unit-wise and claimed from the assessee's total income without setting off losses of one SEZ unit against profits of other SEZ units and without aggregating export or total turnover across units; the AO is directed to recompute accordingly. Interest and other specified miscellaneous incomes attributable to SEZ units are eligible for s.10AA deduction and must be allowed. Foreign tax credit relating to income eligible for s.10AA is to be permitted. A s.37(1) claim for foreign taxes not claimable under ss.90/91 is remanded to the AO for fresh scrutiny. Disallowance under s.14A r.w. r.8D and addition for brand-building expenditure are deleted. Deduction under s.32AC is allowed.
ITAT directed that deduction under s.10AA be computed unit-wise and claimed from the assessee's total income without setting off losses of one SEZ unit against profits of other SEZ units and without aggregating export or total turnover across units; the AO is directed to recompute accordingly. Interest and other specified miscellaneous incomes attributable to SEZ units are eligible for s.10AA deduction and must be allowed. Foreign tax credit relating to income eligible for s.10AA is to be permitted. A s.37(1) claim for foreign taxes not claimable under ss.90/91 is remanded to the AO for fresh scrutiny. Disallowance under s.14A r.w. r.8D and addition for brand-building expenditure are deleted. Deduction under s.32AC is allowed.
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