https://www.taxtmi.com/caselaws?id=391978 ITAT Visakhapatnam held that SEZ trading activity involving import for re-export fell within section 10AA because the SEZ framework treats such trading as part of services, so the deduction was allowable. It further held that ocean freight paid to agents of foreign shipping lines was covered by CBDT Circular No. 723, making sections 194C and 195 inapplicable and preventing disallowance under section 40(a)(ia). On transfer pricing, the Tribunal rejected functionally dissimilar external comparables, preferred internal segmental comparables and internal TNMM, and treated receivables as closely linked to sales rather than a separate loan, so the adjustment was deleted. en-us Wed, 05 Feb 2020 00:00:00 +0530 Tue, 11 Feb 2020 08:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391978 ITAT Visakhapatnam held that SEZ trading activity involving import for re-export fell within section 10AA because the SEZ framework treats such trading as part of services, so the deduction was allowable. It further held that ocean freight paid to agents of foreign shipping lines was covered by CBDT Circular No. 723, making sections 194C and 195 inapplicable and preventing disallowance under section 40(a)(ia). On transfer pricing, the Tribunal rejected functionally dissimilar external comparables, preferred internal segmental comparables and internal TNMM, and treated receivables as closely linked to sales rather than a separate loan, so the adjustment was deleted. Case-Laws Income Tax Wed, 05 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391978