YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI
In the result the appeal of the assessee is partly allowed for statistical purposes
ITA 1330/CHNY/2023[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13
Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)
For Appellant: Shri. Ajit Kumar Jain, CA by VirtualFor Respondent: Shri. A. Sasikumar, CIT
Section 10ASection 250Section 92C(3)Section 92D
…in the context of section 80-O of the Act, states that the deduction will be available even where the foreign recipient of the services utilizes the benefits of such services in India as held by the Authority for Advance Ruling in the case of A.S. Mani v CIT (227 ITR 380). :-14-: ITA. No: 1330/Chny/2023 Therefore, the provision of service by the assessee to a non-resident foreign customer outside India from SEZ is export of service and eligible for deduction under section 10AA of the Act. Further, the ld. AR stated that the SEZ Act to have an overriding effect: Section 51 of the SEZ Act reads as follows: “The…