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    <title>2007 (3) TMI 778 - ITAT BANGALORE</title>
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    <description>Conversion of a partnership firm into a company, followed by approval as an STP unit, did not disqualify the undertaking from section 10A exemption. The conversion was treated as a transformation, not a transfer, and therefore did not amount to formation of the business by splitting up or reconstruction of an existing undertaking. The CBDT circulars recognising conversion of an existing DTA unit into an STP unit were treated as binding on tax authorities. Section 10A(9) also did not apply, because the conversion did not involve transfer of ownership or beneficial interest in the manner contemplated by that provision. The exemption claim was upheld.</description>
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    <pubDate>Fri, 16 Mar 2007 00:00:00 +0530</pubDate>
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      <title>2007 (3) TMI 778 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=187714</link>
      <description>Conversion of a partnership firm into a company, followed by approval as an STP unit, did not disqualify the undertaking from section 10A exemption. The conversion was treated as a transformation, not a transfer, and therefore did not amount to formation of the business by splitting up or reconstruction of an existing undertaking. The CBDT circulars recognising conversion of an existing DTA unit into an STP unit were treated as binding on tax authorities. Section 10A(9) also did not apply, because the conversion did not involve transfer of ownership or beneficial interest in the manner contemplated by that provision. The exemption claim was upheld.</description>
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      <pubDate>Fri, 16 Mar 2007 00:00:00 +0530</pubDate>
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