https://www.taxtmi.com/caselaws?id=389653 Deduction under ss. 10A/10AA turned on whether conversion of an existing EPZ unit into an SEZ unit constitutes "beginning to manufacture" in the SEZ so as to trigger a fresh tax holiday. The ITAT held it does not: manufacturing had commenced earlier, and conversion was not a new undertaking; s. 10A(1A) applies to newly set-up SEZ units, while converted units remain governed by s. 10A(1) until s. 10AA becomes operative. In light of s. 10A(7B) and the scheme introducing s. 10AA, the assessee was held eligible for deduction under s. 10AA(1)(ii) for the year, subject to conditions. Disallowance under s. 40(a)(i) r/w s. 9(1)(vii) for alleged failure to deduct TDS u/s 195 on foreign agent commission was remanded to CIT(A) for fresh adjudication on merits. en-us Wed, 11 Dec 2019 00:00:00 +0530 Fri, 02 Jan 2026 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389653 Deduction under ss. 10A/10AA turned on whether conversion of an existing EPZ unit into an SEZ unit constitutes "beginning to manufacture" in the SEZ so as to trigger a fresh tax holiday. The ITAT held it does not: manufacturing had commenced earlier, and conversion was not a new undertaking; s. 10A(1A) applies to newly set-up SEZ units, while converted units remain governed by s. 10A(1) until s. 10AA becomes operative. In light of s. 10A(7B) and the scheme introducing s. 10AA, the assessee was held eligible for deduction under s. 10AA(1)(ii) for the year, subject to conditions. Disallowance under s. 40(a)(i) r/w s. 9(1)(vii) for alleged failure to deduct TDS u/s 195 on foreign agent commission was remanded to CIT(A) for fresh adjudication on merits. Case-Laws Income Tax Wed, 11 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389653