2015 (3) TMI 219

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.... This appeal by the Revenue is directed against the order of the Ld. Commissioner of Income Tax (Appeals-IV), New Delhi dated 25.6.2013 pertaining to assessment year 2009-10. 2. The grounds raised read as under:-     (a) In allowing deduction of Rs. 20,83,365/- u/s. 10B of the Act despite the fact that the assessee is merely engaged in testing of equipment to be exported. T....

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....ut abroad and not in the SEZ unit to be eligible for deduction u/s. 10B of the Act.     (e) In holding that even if the manufacturing is outsourced and done in an area outside SEZ then also it shall be eligible for deduction u/s. 10B of the I.T. Act, 1961. 3. At the outset, Ld. Counsel of the assessee submitted that the issue is covered in favor of the assessee by the decision....

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....r under appeal as well as orders for A.Y. 2007-08 and A.Y. 2008-09, written submissions of the appellant for A.Y. 2007-08 and 2008-09, orders of the Ld. CIT(A) for A.Y. 2007-08 and 2008-09, and other of the ITAT for A.Y. 2007-08 and 2008-09. Erection and commissioning income has also been shown by the appellant company for A.Y. 2008-09 and was duly considered for purpose of allowing deduction u/s.....

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....en there is no change in the working process of the assessee company for the year under consideration, and the AO has also passed the order relying on observations made in AY 2008-09, I have no reason to differ with the observations made by my Ld. Predecessor CIT(A) in earlier years i.e. A.Y. 2007-08 and 2008-09. Since ITAT has allowed the claim of the appellant company for AY 2007-08 and AY 2008-....