https://www.taxtmi.com/caselaws?id=784489 Interpretation of ss. 10A(7B) and 10AA: on insertion of s. 10A(7B), all SEZ units fall under s. 10AA; an SEZ unit cannot claim an additional five-year deduction after exhausting the original ten-year block, and is eligible only for the unexpired portion of ten consecutive years; deduction for the relevant AY under s. 10AA(1)(i) was allowed subject to statutory conditions. Scope of "export" for s. 10AA: only the restrictive definition in Explanation 1 applies; supplies to DTA/other SEZ/EOU were excluded; computation was remanded to AO accordingly. s. 35(2AB): absence of Form 3CL during assessment could not by itself defeat the claim; matter remanded for verification and allowance if valid. s. 14A: with no exempt income and sufficient interest-free funds, disallowance was deleted. s. 36(1)(iii): no nexus shown and own funds exceeded advances, so disallowance was deleted. PF/ESI: payment on next working day due to holiday was allowed; balance sustained. Prior-period income: alleged double reduction was rejected and addition deleted. Bad debts and pre-clinical test provision: remanded for verification of fresh evidence. en-us Thu, 01 Jan 2026 00:00:00 +0530 Tue, 06 Jan 2026 08:48:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784489 Interpretation of ss. 10A(7B) and 10AA: on insertion of s. 10A(7B), all SEZ units fall under s. 10AA; an SEZ unit cannot claim an additional five-year deduction after exhausting the original ten-year block, and is eligible only for the unexpired portion of ten consecutive years; deduction for the relevant AY under s. 10AA(1)(i) was allowed subject to statutory conditions. Scope of "export" for s. 10AA: only the restrictive definition in Explanation 1 applies; supplies to DTA/other SEZ/EOU were excluded; computation was remanded to AO accordingly. s. 35(2AB): absence of Form 3CL during assessment could not by itself defeat the claim; matter remanded for verification and allowance if valid. s. 14A: with no exempt income and sufficient interest-free funds, disallowance was deleted. s. 36(1)(iii): no nexus shown and own funds exceeded advances, so disallowance was deleted. PF/ESI: payment on next working day due to holiday was allowed; balance sustained. Prior-period income: alleged double reduction was rejected and addition deleted. Bad debts and pre-clinical test provision: remanded for verification of fresh evidence. Case-Laws Income Tax Thu, 01 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784489