Section 10A Deduction Denied: Export Sale Proceeds Not Received in Convertible Foreign Exchange Without RBI Approval for Investment.

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....Deduction u/s. 10A - export sales - non-receipt in convertible foreign exchange - Even for the sake of discussion, the plea of the assessee of converting the outstanding sale proceeds into overseas direct investment to be treated as compliance of provision of section 10A(3) then also it cannot be accepted as there is no proper approval of Reserve Bank of India for capitalization of outstanding export sale proceeds. - AT....