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    <description>An SEZ unit&#039;s process was examined to determine whether it amounted to manufacture for deduction under Section 10AA of the Income-tax Act, 1961. The Assessing Officer treated the activity as insufficient because the raw material and finished product were said to be the same, but the appellate authorities accepted the process-flow evidence, the nature of the semi-finished material, and the commencement certificate, finding a change in name, character or use. On those concurrent factual findings, the activity was treated as manufacture under the Special Economic Zones Act, 2005, the deduction was upheld, and no substantial question of law was found to arise.</description>
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