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    <title>2026 (1) TMI 446 - ITAT PUNE</title>
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    <description>The dominant issue was whether deduction under s.10AA could be denied for AY 2018-19 on the ground that export/forex proceeds were not received in India within the prescribed period. Relying on Tribunal precedent noting that a specific statutory time-limit for repatriation was proposed only with effect from 01.04.2024, the Tribunal held that no such condition applied for the year in question; consequently, denial of s.10AA on this ground was set aside and the deduction was allowed. The Tribunal also held that the first appellate authority had failed to adjudicate (i) the challenge to adjustments made via intimation u/s 143(1), and (ii) pro-rata s.10AA impact linked to employees&#039; PF/ESI disallowance; both issues were remanded for fresh decision after granting one final opportunity.</description>
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    <pubDate>Mon, 24 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 446 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=784690</link>
      <description>The dominant issue was whether deduction under s.10AA could be denied for AY 2018-19 on the ground that export/forex proceeds were not received in India within the prescribed period. Relying on Tribunal precedent noting that a specific statutory time-limit for repatriation was proposed only with effect from 01.04.2024, the Tribunal held that no such condition applied for the year in question; consequently, denial of s.10AA on this ground was set aside and the deduction was allowed. The Tribunal also held that the first appellate authority had failed to adjudicate (i) the challenge to adjustments made via intimation u/s 143(1), and (ii) pro-rata s.10AA impact linked to employees&#039; PF/ESI disallowance; both issues were remanded for fresh decision after granting one final opportunity.</description>
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      <pubDate>Mon, 24 Nov 2025 00:00:00 +0530</pubDate>
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