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    <title>2023 (4) TMI 105 - ITAT AHMEDABAD</title>
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    <description>Deduction under section 10AA was held available where the claim was made in a revised return and the audit report was filed during assessment, because the then-applicable law did not require the claim to be confined to a return filed within the due date. Conversion of a proprietorship into a partnership was treated as a change in constitution, not reconstruction or split-up of the undertaking, so the deduction was not denied. Lease of some machinery did not defeat eligibility because the unit was not formed by transfer of previously used machinery. Sales to merchant exporters as deemed exports also did not bar the claim, as the relevant year&#039;s law did not yet require receipt of sale proceeds in convertible foreign exchange.</description>
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