2018 (10) TMI 1392

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....ri Santosh Karnani, Sr. D.R. ORDER PER PRADIP KUMAR KEDIA - AM: The captioned appeal has been filed at the instance of the assessee against the order of the CIT(A)-13, Ahmedabad ('CIT(A)' in short), dated 27.02.2015 arising in the assessment order dated 13.02.2014 passed by the Assessing Officer (AO) under s. 143(3) of the Income Tax Act, 1961 (the Act) concerning assessment year 2011-12.....

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....O restricted the exemption under s.10A of the Act and denied exemption on profits attributable to convertible foreign exchange brought into India after six months from the end of the relevant financial year. The CIT(A) also sustained the action of the AO in first appeal. Addressing the controversy, the learned AR referred to provisions of Section 10A(3) of the Act and submitted that an assessee un....

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.... 100% export oriented units has been extended whereby such undertakings are given liberty to realize export proceeds within a period of twelve months from the date of export on or after September 1st, 2004. It is the case of the assessee that the assessee has realized the sale proceeds within the extended period of twelve months from the date of export. The learned AR thus submitted that in view o....

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....in the extended period allowed by the competent authority namely RBI in terms of Master Circular of general nature. A perusal of the Master Circular clearly shows that the competent authority has extended the period of obligation cast upon the exporters to receive and bring convertible foreign exchange in India within twelve months from the date of export. Thus, in our view, deduction under s.10A ....