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“export oriented unit”

DeductionsSection 10BSection 10B105 judgments

The decision most relied on for export oriented unit is CIT v. Hewlett Packard Global Soft Ltd. (87 Taxmann.com 182), cited in 120 judgments on BharatTax.

Leading authorities on export oriented unit

CIT v. Hewlett Packard Global Soft Ltd.
87 Taxmann.com 182 · 2017 · High Court
120
citing judgments

Incidental income like interest on bank deposits or staff loans, earned by an undertaking eligible for deductions under sections 10A and 10B, constitutes part of the 'profit and gains of the undertaking' and is thus eligible for 100% deduction, as it arises in the ordinary course of the export business even if not a direct result of export.

Chicago Pneumatic India Ltd. v. DCIT
15 SOT 252 · 2007 · ITAT
111
citing judgments

The Assessing Officer must grant the correct deduction after due verification of claims made by the assessee, even if not perfectly articulated initially. This principle applies in assessment proceedings, including those involving specific deductions like those for export-oriented units under Section 10B.

CIT v. Motorola India Electronics (P.) Ltd.
46 Taxmann.com 167 · 2014 · High Court
77
citing judgments

Interest income derived from funds of an undertaking, such as from FDRs or EEFC accounts, forms part of the "profits of the business of the undertaking" and is eligible for deduction under Sections 10A and 10B, provided there is a direct nexus with the business. This deduction applies to the entire income from the business of the undertaking, not solely to profits from export activities.

CIT v. Regency Creations Ltd.
353 ITR 326 · 2013 · High Court
43
citing judgments

For a valid claim of deduction under Section 10B of the Income-tax Act, especially for a 100% Export Oriented Unit under Explanation 2(iv), approval from the Director STPI requires mandatory ratification by the specified "Board". An alternative claim for deduction under Section 10A, even if not initially raised before the Assessing Officer, can be directed for consideration by the Tribunal.

Bush Boake Allen (India) Ltd. v. ACIT
273 ITR 152 · 2005 · High Court
29
citing judgments

Allocation of R&D expenditure to eligible units is not clearly warranted when R&D units are maintained within manufacturing units and not as independent entities. This is particularly relevant when the Assessing Officer allocates R&D expenses to Export Oriented Units (EOUs) in the ratio of turnover, and the Commissioner (Appeals) has deleted such additions.

CIT v. Technovate E Solutions P.Ltd.
354 ITR 110 · 2013 · High Court
12
citing judgments

Approval from the Director of STPI is sufficient for claiming deduction under Section 10A of the Income-tax Act, even for Export Oriented Units (EOUs).

Sterling Agro Products Processing (P) Ltd. v. ACIT
48 SOT 80 · 2011 · ITAT
11
citing judgments

A business processing gherkins (cucumbers) into gherkin pickles, through various manufacturing processes, is entitled to deduction under Section 10B of the Income-tax Act, 1961.

Somasundraram & Bros. v. CIT
282 ITR 389 · 2006 · High Court
10
citing judgments

Interest income earned from loans advanced to a unit in a Special Economic Zone (SEZ) or Export Oriented Unit (EOU) is taxable under the head 'income from other sources' and is not eligible for deduction under Section 10B.

Judgments citing export oriented unit

Deputy Commissioner of Income Tax 1(1)(2), Mumbai vs. Hindustan Unilever Limited, Mumbai

ITA 929/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80H

computation of income, the assessee claimed a deduction under section 10B of the Act on the profits and gains from 100% Export-Oriented Unit (“EOU”) at Etah and Chorwad. During the assessment proceedings, the assessee was asked to show cause why the miscellaneous income of the exempt unit ... course of assessment proceedings, the Assessing Officer noticed that assessee claimed exemption u/s 10B on the profit and gains from 100% of export oriented unit Etah amounting to Rs.5,03,65,774/- which included miscellaneous income of Rs.30,361. The assessee submitted that the miscellaneous income consists of realisation from

Hindustan Unilever Limited, Mumbai vs. Dy.CIT-1(1)(2), Mumbai

In the result, the appeal by the Revenue and cross-objection by the

ITA 1041/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05

Bench: Shri Om Prakash Kant

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80HSection 8O

computation of income, the assessee claimed a deduction under section 10B of the Act on the profits and gains from 100% Export-Oriented Unit (‘EOU”) at Etah and Chorwad. During the assessment proceedings, the assessee was asked to show cause why the miscellaneous income of the exempt unit ... course of assessment proceedings, the Assessing Officer noticed that assessee claimed exemption u/s 10B on the profit and gains from 100% of export oriented unit Etah amounting to Rs.5,03,65,774/- which included miscellaneous income of Rs.30,361. The assessee submitted that the miscellaneous income consists of realisation from

Uttarakhand Vikas Samiti, Udaipur vs. DCIT, CPC / ITO, Ward Exemption, Udaipur

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 257/JODH/2025[2018-19]Status: DisposedITAT Jodhpur28 Jan 2026AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleuttarakhand Vikas Samiti Vs. Dcit, Cpc/Ito, Ward Exemption, 117, Main Road, Bhupalpura, Udaipur - 313001 Udaipur - 313001 Pan No. Aaatu 3935 G Assessee By Shri Yogesh Pokharna, C.A. (Physical) Shri K.C. Meena, Addl. Cit-Dr (Virtual) Revenue By Date Of Hearing 13.01.2026. Date Of Pronouncement 28.01.2026. Order Dr. Mitha Lal Meena, A.M.: The Appeal By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax, Appeal, Addl/Jcit (A) Patna [Hereinafter Referred To As “The Jcit Appeal”] Dated 24.01.2025 With Respect To Assessment Year 2018-19 Challenging Therein Confirmation Of Addition Of Rs. 6,00,000/- Without Appreciating Facts Of The Case.

Section 10BSection 11Section 119(2)Section 119(2)(b)Section 12ASection 143(1)Section 8

applicable in the present case. As in that case, the issue involved was pertaining to exemption to 100% Export Oriented Unit. Sub Section 8 grants a right to the assessee to withdraw himself from the provisions of Section 10B. Thus, Sub Section 8 of Section 10B deals in entire different

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

Engines, Spares, Components (including Bought-Outs) thereof & Generating Sets, service of Engines & Gensets / Generating Sets & Allied Equipment, etc. Assessee also has a 100% Export Oriented Unit at Pirangut which is engaged in manufacture and exports of internal combustion engines and its accessories and generating sets and accessories. The returns filed

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR
Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

Engines, Spares, Components (including Bought-Outs) thereof & Generating Sets, service of Engines & Gensets / Generating Sets & Allied Equipment, etc. Assessee also has a 100% Export Oriented Unit at Pirangut which is engaged in manufacture and exports of internal combustion engines and its accessories and generating sets and accessories. The returns filed

Alex Grinders Private Limited, Mumbai vs. ITO 4(1)(1), Mumbai

In the result, the addition so made and sustained by the Ld

ITA 2334/MUM/2025[2013-2014]Status: DisposedITAT Mumbai24 Nov 2025AY 2013-2014

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2013-14 Alex Grinders Pvt. Ltd., Dcit, Circle-4(1)(1), 32, Diamond Queen, Aayakar Bhavan, West Avenue, Santacruz, Vs. Maharshi Karve Road, Mumbai-400054. New Marine Lines, Pan : Aaaca3664K Churchgate, Mumbai-400020. (Appellant) (Respondent) For Assessee : Shri Bharat Kumar For Revenue : Shri Surendra Mohan, Sr.Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 24-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld. Cit(A)‟], Dated 04-02-2025, Pertaining To Assessment Year (Ay) 2013-14, Wherein The Assessee Has Taken The Following Ground(S) Of Appeal:

For Appellant: Shri Bharat KumarFor Respondent: Shri Surendra Mohan, Sr.DR
Section 142(1)Section 143(3)Section 37(1)

Rakshak aani General Kamgar Union (Reg). The assessee-company is having registered office at Mumbai and factory at Lonawala. It is a 100% Export oriented unit and is manufacturing various parts as per requirement of foreign customers. During this year, the assessee-company had a labour problem at Lonavala factory

M/S Genpact Infrastructure (Hyderabad) Pvt. Ltd., New Delhi vs. DCIT, New Delhi

Appeal of the assessee is partly allowed

ITA 3394/DEL/2016[2010-11]Status: DisposedITAT Delhi09 Jul 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 10ASection 142(1)Section 143(2)Section 143(3)Section 1OSection 234BSection 250

complete code in themselves and deal with profits and gains derived by the assessee of a special nature and character like 100% Export Oriented Units (EOUs.) situated in Special Economic Zones (SEZs), STPI, etc., where the entire profits and gains of the entire Undertaking making 100% exports of articles including

Kbs Creation Ltd, Mumbai vs. Dy Comm. of Income Tax -Circle 24(1), Mumbai

In the result, the concise ground of appeal of the assessee is allowed

ITA 6477/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Jun 2025AY 2021-22

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10ASection 143(3)Section 254(1)Section 80ISection 92C

length operating profit (OP) @ 2.13%/2.56% respectively as: a) A low level of Operating Profit (OP) computed @ 2.13%, for a fully integrated export-oriented unit manufacturing Diamond Studded Jewellery 2 KBS Creations(AY: 2021-22) will result into arriving at non-economic profit at net level from the angle ... determine ALP.To support such submission, the assessee stated that such low level of operating profit computed at 2.13% for a fully integrated export oriented unit manufacturing 7 KBS Creations(AY: 2021-22) diamond,studded Jewellery will result arriving at non-economic profit at net level from the angel

Emerson Electric Company (India)Pvt. Ltd, Mumbai vs. DCIT 1(2) (1) Jurisdictional Assessing Officer, Mumbai

In the result, this ground of appeal is allowed

ITA 2323/MUM/2022[2018-19]Status: DisposedITAT Mumbai28 May 2025AY 2018-19

Bench: Shri Pawan Singh&Girish Agrawal(Physical Hearing) Emerson Electric Company (India) Dcit, Range-1(2)(1), Mumbai Private Limited, Delphi ‘B’ Wing, Vs Aayakar Bhawan, 601-603, Orchard Avenue, Mumbai Hiranandani Business Park, Powai, Mumbai-400076. [Pan No. Aaace1260B] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 144BSection 144C(13)Section 254(1)

assessee submits that the assessee has a manufacturing division in Nasik namely Emerson Engineering Export Centre (EEEC-Nasik), which is a 100% export oriented unit, registered with STPI, set up in 2016 and is engaged in manufacturing of electronic cabinets, panels including system cabinets, marshalling cabinets and power distribution panels ... that there is no dispute that the assessee has set up unit in Nasik namely Emerson Engineering Export Centre (EEEC-Nasik), being 100% export oriented unit, newly set up unit is engaged in manufacturing of electronic cabinets, panels including system cabinets, marshalling cabinets and power distribution panels, components and parts

Gallagher Service Center LLP (Formerly Known As Gallagher Operations Support Services P Ltd), Pune vs. Assistant Commissioner of Income-Tax, NFAC, Delhi

In the result, the Ground Number 6 is Partly Allowed for Statistical purpose

ITA 679/PUN/2022[2018-19]Status: DisposedITAT Pune24 Mar 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.679/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Gallagher Services Center V Additional/Joint Llp, S Commissioner Of Income 401, Delta 2, Gigaspace It Tax. Park, Vimannagar, Pune – 411014. Pan: Aaqfg7417F Appellant/ Assessee Respondent /Revenue Assessee By Shri M.P.Lohia – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 23/01/2025 Date Of Pronouncement 24/03/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Assessment Order Of Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961; Dated 15.07.2022 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, The Appellant Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D)

Section 143(3)Section 144Section 144BSection 253(1)(d)

service provider engaged in providing back-office support in insurance domain exclusively to its group companies. During the impugned year, the assessee has Export Oriented Units (EOU) in Pune, Bengaluru, Shimoga and Kolhapur which are registered with the Software Technology Parks in India(STPI). The Return of Income filed

Excelra Knowledge Solutions Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 202/HYD/2023[2020-21]Status: DisposedITAT Hyderabad23 Jan 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.202/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Excelra Knowledge Vs. Dy. Cit Solutions (P) Ltd, Circle 8(1) Hyderabad Hyderabad Pan:Aafcg5715Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 25/11/2024 घोषणा की तारीख/Pronouncement: 23/01/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated10/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds:

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 10ASection 143(1)Section 438Section 43B

Account. He has further contended that since the deposits with banks were made out of the export proceeds and assessee is a 100% export oriented unit located in SEZ have to receive its sale proceeds in convertible foreign exchange. Therefore, the entire turnover is from exports which is eligible ... deduction u/s 10AA in respect of all the incomes earned by it. The quantum of deduction to be the income of the export oriented unit. He has also referred to the decision of the Hon'ble Delhi High Court in the case of CIT vs. Vasishta Chay Vyapar

Value Labs LLP, Hyderabad vs. ACIT Circle-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 229/HYD/2022[2009-10]Status: DisposedITAT Hyderabad23 Jan 2025AY 2009-10

Bench: Shri Manjunatha. G & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 229/Hyd/2022 ("नधा"रण वष" / Assessment Year: 2009-10) Value Labs Llp, Vs. Acit, Hyderabad. Circle-8(1), [Pan : Aakfv2276K] Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

For Appellant: Shri P. Murali Mohan Rao, ARFor Respondent: Shri Suresh Babu KN, Sr. AR
Section 10ASection 41(1)Section 56

Partnership firm deriving income from the business Value Labs LLP, Hyderabad of development and export of so"ware. It is a 100% export oriented unit covered by the provisions of 10A of the Income Tax Act, 1961 (the Act). For the assessment year 2008/09, it filed the return of income ... miscellaneous receipts of Rs. 6,96,068/-being the profits u/s 41(1) has direct nexus with profits of export oriented unit, Pursuant to the said order, the learned Assessing Officer passed an order dated 31/12/2018, determining the assessee’s taxable income

Dy. Commissioner of Income Tax, Mumbai vs. M/S Infrasoft Technologies Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 5769/MUM/2024[2006-07]Status: DisposedITAT Mumbai31 Dec 2024AY 2006-07

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2006-07

For Appellant: Shri Tarang Mehta, ARFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10ASection 143Section 143(3)Section 254

which the company already had the lease in its favour. 6.1.15 To substantiate the intention of the appellant company to establish a new export oriented unit registered with STPI along with the purchase of new plant and machinery at the second floor of the building, and to shift the present

Orchid Pharma Limited, Chennai vs. DCIT, Chennai

In the result, the appeal of the assessee is partly allowed

ITA 73/CHNY/2017[2012-13]Status: DisposedITAT Chennai11 Dec 2024AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.73/Chny/2017 निर्ाारण वर्ा /Assessment Years: 2012-13

For Appellant: Shri B.Ramakrishnan, FCA & ShriFor Respondent: Shri A.Sasikumar, CIT
Section 143(3)Section 92A(2)(i)

noted that the assessee added provisions for rebates and discount to the tune of Rs.6,79,24,142/- while computing its export oriented unit (EOU) operations and Rs.33,20,75,858/- for its non- EOU operations. The Ld. AO allowed assessee’s claim in respect of Rs.6

Lanco Solar (Gujarat) Private Limited, Hyderabad vs. ITO., Ward-16(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 906/HYD/2024[2018-19]Status: DisposedITAT Hyderabad27 Nov 2024AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

For Appellant: Shri Rakesh Joshi, CAFor Respondent: : Shri Gudimella V P Pavan
Section 80I

section 10B held that benefit under section 10 is always attached to the industrial undertaking irrespective of the fact who owns it 100% export oriented unit and enjoying tax exemption under section 10B merged with assessee, would be entitled to same benefit with respect to said unit even after merger

Lanco Solar (Gujarat) Private Limited, Hyderabad vs. ITO., Ward-16(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 905/HYD/2024[2017-18]Status: DisposedITAT Hyderabad27 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita Nos. 905 & 906/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) Lanco Solar (Gujarat) Vs. Income Tax Officer Private Limited, Hyderabad Ward 16(1) Pan:Aabcl1095J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rakesh Joshi, Ca राज" व "ारा/Revenue By:: Shri Gudimella V P Pavan Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 27/11/2024 आदेश/Order

For Appellant: Shri Rakesh Joshi, CAFor Respondent: : Shri Gudimella V P Pavan
Section 80I

section 10B held that benefit under section 10 is always attached to the industrial undertaking irrespective of the fact who owns it 100% export oriented unit and enjoying tax exemption under section 10B merged with assessee, would be entitled to same benefit with respect to said unit even after merger

ITO, Lower Parel vs. Sohit Shravankumar Sadh, Lower Parel

In the result, the appeal filed by the Revenue is dismissed

ITA 3180/MUM/2024[2018]Status: DisposedITAT Mumbai12 Nov 2024

Bench: Ms. Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Income Tax Officer Sohit Shravankumar Sadh Room No. 213, 3Rd Floor, A-2, Unit No. 79, Shah & Amp, Piramal Chambers, Lalbaug, Vs. Nahar Industrial Estate, Mumbai – 400 012 S J Road, Mumbai-400 013

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Rajesh Meshram
Section 143(2)Section 143(3)Section 250Section 56(2)(x)

account of difference in the stamp duty value. It is observed that the assessee had acquired an undertaking (export oriented unit (EOU)) with all its assets and liabilities which includes Industrial Gala nos. 85 to 86 from M/s. SK International Export Co. as a going concern for a slum sale

Shikhar Exports, New Delhi vs. Aito Ward - 54(1), New Delhi

ITA 8518/DEL/2019[2011-12]Status: DisposedITAT Delhi18 Oct 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Sudhir Kumarshikhar Exports Vs. Aito, Ward – 54(1) C/O. Pranshu Goel, C.A. New Delhi 5A/3A, Ansari Road Darya Ganj, New Delhi-110 002 Pan: Aadfs 6406 M (Appellant) (Respondent) Assessee By : Shri Pranshu Goel, C.A. & Shri Aditya Gupta, Adv. Revenue By: Shri V. K. Dubey, Sr. D.R. Date Of Hearing 15/10/2024 Date Of Pronouncement 18/10/2024

For Appellant: Shri Pranshu Goel, C.A. and Shri Aditya Gupta, AdvFor Respondent: Shri V. K. Dubey, Sr. D.R
Section 10BSection 143(3)Section 147Section 148Section 150(1)Section 150(2)

partners in the assessee firm Smt. Kalawati Sadh and Shri Rajeev Sadh having equal profit sharing ratio. Since the assessee is a 100% Export Oriented Unit (EOU), it claimed deduction under section 10B of the Act for the profits derived from the said 100 % EOU. This claim has been made

Asst. Commissioner of Income Tax, Vijayawada vs. Fysolate Technologies, Vijayawada

In the result, appeal of the Revenue is dismissed

ITA 182/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam15 Jul 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

For Appellant: Sri Mithilesh SannareddyFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 143(2)Section 143(3)Section 92C

than 10% when compared to the export activities carried out by the assessee which is more than 75% as the assessee is an export oriented unit. S. Comparable Name Turnover (In Export Export Export No INR) Income (In income Filter INR) (%) (75%) 1. Nagarjuna Herbal Concentrates ... considered view that the fresh comparables selected by the TPO do not have export performance and whereas the assessee is a 100% export oriented unit and hence these comparables are fit to be compared with that of the AE M/s. Laila Nutra as a Tested Party. It is also found

Advance Power Display Systems Ltd, Andheri - East vs. Dy Commissioner of Income Tax -9(1)(1), Aaykar Bhavan, Church Gate, Mumbai

In the result, the appeals of the assessee are allowed

ITA 1535/MUM/2024[AY 2014-15]Status: DisposedITAT Mumbai11 Jul 2024

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

For Appellant: Shri Y.P. Trivedi/ Shri Nishit Gandhi & Smt. UshaFor Respondent: Shri Uodal Raj Singh, Sr. D/R
Section 40ASection 92CSection 92C(2)

light of Rule 18(6) of the ITAT Rules. 5. Briefly stated the facts of the case and that the assessee is 100% Export Oriented Unit (EOU) engaged in the business of manufacturing of Switch Mode Power Supplies (SMPS) used in computer industry and information technology applications with end users