“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

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

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

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

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

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

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

Lupin Ltd., Mumbai vs. The Dy CIT, Circle-3(4), Mumbai

In the result, the appeal of the assessee in I

ITA 77/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 Mar 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Rajan Vora, Shri PranayFor Respondent: Ms. Manju Thakur, Sr. DR

Section 10ASection 115JSection 143(3)Section 154Section 271(1)(c)Section 37(1)

77/M /21, 1241 to 1242/M/ 2021 & C.O. 01/M /2022 Lupin Limited Allowability of deduction under setion 10AA of 100% of profits derived from Export Oriented Unit before considering the additions/deletions 20. The assessee through additional ground is contending that the deduction under section 10AA of the Act with respect ... contended that the deduction u/s 10B of the Act should be computed with reference to Profits and gains derived by 100% Export Oriented Units (Pril, Oral and Goa) from M/s. Lupin Limited 21 exports without deducting allowances under the Income tax Act, i.e., the claim of the assessee is that

Asstt. CIT -Circle-3(4), Mumbai vs. M/S. Lupin Ltd., Mumbai

In the result, the appeal of the assessee in I

ITA 1241/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 Mar 2024AY 2013-14

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Rajan Vora, Shri PranayFor Respondent: Ms. Manju Thakur, Sr. DR

Section 10ASection 115JSection 143(3)Section 154Section 271(1)(c)Section 37(1)

Lovely Promoters Private Limited, Kolkata vs. ACIT, Central Circle, Ajmer

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a

Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh

Asst CIT (Ltu) 1, Mumbai vs. Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1248/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Dec 2023AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar, ARFor Respondent: Ms. A. Alankrutha, Sr. DR

Section 10BSection 115JSection 14ASection 234BSection 271(1)(c)Section 32(1)(iia)Section 37Section 40Section 43BSection 80I

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No

Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd), Mumbai vs. Addl CIT Ltu, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1065/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Dec 2023AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar, ARFor Respondent: Ms. A. Alankrutha, Sr. DR

Section 10BSection 115JSection 14ASection 234BSection 271(1)(c)Section 32(1)(iia)Section 37Section 40Section 43BSection 80I

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No

ACIT-24(1), Mumbai vs. M/S. H K Designs (India) LLP, Mumbai

The appeal of the assessee is allowed

ITA 2050/MUM/2023[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 10A

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

ACIT(OSD), Ward-22(1), New Delhi vs. S.S. Gas Lab Asia P. Ltd., Delhi

In the result, cross objection of the assessee is allowed and appeal of the revenue is dismissed

ITA 3246/DEL/2019[2008-09]Status: DisposedITAT Delhi05 Oct 2023AY 2008-09

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaacit(Osd), Vs. S. S. Gas Lab Asia P. Ltd, Ward-22(1), A-6/3, Jhilmil Industrial Area, New Delhi Shahdara, Delhi (Appellant) (Respondent) Pan: Aakcs1928C Co No. 54/Del/2023 (In Ita No. 3246/Del/2019) (Assessment Year: 2008-09) Acit(Osd), Vs. S. S. Gas Lab Asia P. Ltd, Ward-22(1), A-6/3, Jhilmil Industrial Area, New Delhi Shahdara, Delhi (Appellant) (Respondent) Pan: Aakcs1928C Assessee By : Shri Sanjay Kumar Bindal, Ca Revenue By: Shri Anuj Garg, Sr. Dr Date Of Hearing 03/10/2023 Date Of Pronouncement 05/10/2023 O R D E R Per M. Balaganesh, A. M.: 1. The Appeal In Ita No. 3246/Del/2019 Filed By The Revenue & Co No. 54/Del/2023 387/Del/2021 Filed By The Assessee For Ay 2008-09, Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals)-8, New Delhi [Hereinafter Referred To As „Ld. Cit(A)‟, In Short] In Appeal No. 10208/16-17 Dated 08.02.2019 Against The Order Of Assessment Passed U/S 147/143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As „The Act‟) Dated 09.03.2016 By The Assessing Officer, Ito, Ward-22(1), New Delhi (Hereinafter Referred To As „Ld. Ao‟).

For Appellant: Shri Sanjay Kumar Bindal, CAFor Respondent: Shri Anuj Garg, Sr. DR

Section 10BSection 139(1)Section 139(5)Section 143(3)Section 147Section 148

under consideration. It claimed 100% deduction equivalent to the profit earned during the year u/s 10B at Rs.1,30,19,910/- being 100% export oriented unit. However, during the assessment u/s 143(3) dated 02/02/2011 deduction of Rs.1.29,82,355/ was allowed and income of Rs. 37,615/- from other

DCIT, Circle-1, Kalyan vs. M/S Asb International Pvt Ltd, Mumbai

In the result the appeal of the revenue stand dismissed

ITA 1541/MUM/2023[2009-10]Status: DisposedITAT Mumbai27 Sept 2023AY 2009-10

Bench: Amarjit Singh & Shri Sandip Singh Karhaildcit, C-1,Kalyan Vs. M/S. Asb International 1St Floor, Mohan Plaza, Pvt. Ltd. Mayale Naar, E9, E44, Addl. Kalyan(W)- 421301 Ambernath, Industrial Area, Anand Nagar, Ambernath Thane-421506 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaaca8424F Appellant .. Respondent C.O. No. 65/Mum/2023 (A.Y. 2009-10)

For Appellant: Shri. Paras SavlaFor Respondent: Shri. Ajay Chandra

Section 10ASection 10BSection 143(3)Section 147Section 250

Providing for carry forward of business losses and unabsorbed depreciation to units in special economic zones and 100 per cent export oriented units: 20.1 Under the existing provisions of sections 10A and 10B, the undertakings operating in a special economic zone (under section 10A) and 100 per cent export oriented

DCIT, Circle-1(1)-Exemption, New Delhi vs. Hamdard Laboratories (India), New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1311/DEL/2022[2016-17]Status: DisposedITAT Delhi27 Sept 2023AY 2016-17

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2016-17

For Appellant: Shri R.M. Mehta, CAFor Respondent: Shri T James Singson, CIT, DR

Section 10Section 11Section 12ASection 13(2)Section 13(2)(b)Section 13(3)Section 143(3)Section 250

return and accordingly claim should have been allowed-CIT(A) reversed order of AO which was upheld by ITAT-Held, assessee is 100% export oriented unit and had been claiming exemption night from assessment year 2004-05 u/s 108-It may be that claim is to be allowed on year

DCIT-3(2)(1), Mumbai vs. Syntel Private Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 1972/MUM/2023[2016-2017]Status: DisposedITAT Mumbai08 Sept 2023AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2016-17 Dcit-3(2)(1), Syntel Private Limited, Room No. 608, 6Th Floor, Unit No. 112 Sdf Iv, Seepz Aayakar Bhavan, M.K. Road, Vs. Andheri East Mumbai-400096. Mumbai-400020. Pan No. Aaacs 8305 D Appellant Respondent

For Appellant: Mr. Harsh M. KapadiaFor Respondent: Mr. Dr. Kishor Dhule, CIT-DR

Section 10ASection 80A(5)

assessee of a special nature and character like 100% gains derived by the assessee of a special nature and character like 100% Export Oriented Units (EOUs.) situated in Special Economic Zones (SEZs), Export Oriented Units (EOUs.) situated in Special Economic Zones (SEZs), Export Oriented Units (EOUs.) situated in Special Economic

M/S. Zensar Technologies Ltd, Mumbai vs. The DCIT -2(3), Mumbai

In the result, ground No.5 and the additional ground of appeal are allowed

ITA 2907/MUM/2008[2002-2003]Status: DisposedITAT Mumbai28 Aug 2023AY 2002-2003

Bench: Shri Vikas Awasthy & Shrigagan Goyalआअसं.2907/मुं/2008 ("न.व.2002-03) Zensar Technologies Ltd. Magnet House, 2Nd Floor, Narottam Morarjee Marg, Ballard Estate, Mumbai 400 038. Pan: Aaacf-0742-K ...... अपीलाथ"/Appellant बनाम Vs. Dy. Commissioner Of Income Tax, Circle 2(31), Mumbai Mumbai. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By Shri Nitesh Joshi, Advocate : ""तवाद" "वारा/Respondent By : S/Shri Jasdeep Singh, Cit-Dr & Pratap Narayan Sharma, Sr. Ar सुनवाई क" "त"थ/ Date Of Hearing : 02/06/2023 घोषणा क" "त"थ/ Date Of Pronouncement : 28/08/2023 आदेश/Order

For Respondent: S/Shri Jasdeep Singh, CIT-DR &

Section 10ASection 115JSection 234DSection 80HSection 94(7)

assessee is eligible to claim deduction u/s. 80HHE of the Income Tax Act, 1961 (in short ‘the Act’). The assessee has certain Export Oriented Units (EOU), the profits from which are eligible for deduction u/s. 10A of the Act. The said units are located at Software Technology Parks at SEEPZ ... decided on 29/05/2015. He pointed that the Tribunal while deciding similar issue directed the Assessing Officer to include turnover of the export oriented units while computing deduction u/s. 80HHE of the Act. 4. Per contra, Shri Jasdeep Singh representing the Department vehemently defended the findings

Asb International P. Ltd., Ambernath vs. Addl/Jt/Dy/Asstt/CIT/ITO, National E-Assessment Centre, Delhi

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

ITA 921/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Aug 2023AY 2016-17

Section 143(3)Section 144(5)Section 271(1)(c)Section 92C(1)(f)

that assessee is a wholly owned subsidiary of Nissei ASB Machine Co. Ltd. (ASB Japan' or 'AE), was set up as a 100% Export Oriented Unit ('EOU"). It is engaged in manufacturing of injection stretch blow molding machines, molds and parts, components and subassemblies of machines 3 M/s. ASB International

Hindustan Unilever Ltd, Mumbai vs. ITO Cir 1(1)(4), Mumbai

In the result, both the appeal of the assessee and the revenue are partly allowed

ITA 5431/MUM/2011[2001-02]Status: DisposedITAT Mumbai18 Aug 2023AY 2001-02

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10BSection 80HSection 80I

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 ... purpose of exemption under section 10B. The assessee submitted that during the relevant previous year, the assessee had set up a 100% export oriented unit (EOU) in Chorwad for manufacture of crab sticks. The raw material for manufacture of crab sticks is the fish paste manufactured at the existing

Ba Continuum India P.Ltd ( Since Merged Wotj Ba Cotinuum Solutions P. Ltd ), Mumbai vs. ITO WD 9(1)(2), Mumbai

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

ITA 2271/MUM/2011[2006-07]Status: DisposedITAT Mumbai17 Aug 2023AY 2006-07

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2006-07 Ba Continuum India Private Ito, Ward 9(1)(2), Limited (Since Merged With Ba Room No. 226, Vs. Continuum Solutions Pvt. Ltd.), Aayakar Bhavan, Mk Road, Building No. 5, K. Raheja Mind Mumbai-20. Space, Hitech City, Madhapur, Hyderabad-500081. Pan No. Aaccc 3062 D Appellant Respondent

For Appellant: Mr. Nishant Thakkar, AdvFor Respondent: Mr. Salil Mishra, CIT-DR

Section 10ASection 40

Group companies. The assessee centre services) to Countrywide Group companies. The assessee centre services) to Countrywide Group companies. The assessee company is 100% export oriented unit and is registered under the company is 100% export oriented unit and is registered under the company is 100% export oriented unit

Diagold Designs Limited, Mumbai vs. DCIT-12(2)(1), Mumbai

In the result, both the appeals of the assessee, are partly allowed

ITA 445/MUM/2023[2010-11]Status: DisposedITAT Mumbai14 Aug 2023AY 2010-11

Bench: Shri Amit Shukla & Shri Gagan Goyal & Diagold Designs Limited, Cc2070, Bharat Diamond Bourse, Bandra Kurla Complex, Mumbai-400 051 ...... Appellant Vs. Dcit-12(2) (1) Aayakar Bhavan, M. K. Road, Mumbai-400 020 Pan – Aabcd3716 ..... Respondent

For Appellant: Shri Madhur Agrawal, Hitesh TrivediFor Respondent: Smt. Mahita Nair, CIT-DR

Section 10BSection 147Section 148Section 250

with the alleged current year's income. Without Prejudice to the above: Gr.IV. 1. The appellant being Export Oriented Unit (EOU) and the income of the appellant is exempt under section 10B of the Income Tax Act, 1961 for the year under consideration. 2. The appellant prays that the direction ... observation, the fact Diagold Designs Ltd. is not under challenge that sales of the assessee was accepted by the revenue and being 100% export oriented unit sales of the assessee was verified by Indian Customs authorities also. Moreover, assessee produced its stock register for the year under consideration and there

Abhay Chordia, Jaipur vs. DCIT Circle 1, Jaipur

Appeal of the assessee is partly allowed

ITA 291/JPR/2023[2014-15]Status: HeardITAT Jaipur03 Aug 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Deeraj Borad, CAFor Respondent: Sh. Anoop Singh (Addl. CIT)

Section 139(1)Section 143(3)Section 145(3)Section 69C

issued on 18.7.2016 and duly served upon the assessee. The assessee company is engaged in Manufacturing & export of Gems and Jewellery and 100 % Export Oriented Unit established in SEZ at Sitapura Industrial Area, Jaipur through this proprietorship concern namely M/s. Ashoka Jewells. As per information obtained from Investigation Wing, Mumbai

M/S. ACIT 1(1), Mumbai vs. The Hindustan Unilever Ltd, Mumbai

In the result, the appeal of the assesse is partly allowed and the appeal of the revenue stand dismissed

ITA 4033/MUM/2008[2000-2001]Status: DisposedITAT Mumbai16 May 2023AY 2000-2001

Bench: Shri Vikas Awasthy & Shri Amarjit Singhm/S Hindustan Unilever Vs. Addl. Commissioner Of Ltd., Hindustan Lever Income Tax, Range 1(1) House, 165/166 Backbay Mumbai Reclamation Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Acit-1(1), Vs. M/S Hindustan Unilever Room No. 579, Ltd., 165/166, Backbay Aayakar Bhavan, Reclamation Mumbai – 400 020 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Appellant By : Nishant Thakkar & Ms. Jasmin Amalsadvala Respondent By : Chandip Singh Date Of Hearing 09.03.2023 Date Of Pronouncement 16.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assesse & The Revenue Are Pertained To Assessment Year 2000-01 Based On Similar Fact & P A G E | 2

For Appellant: Nishant Thakkar &For Respondent: Chandip Singh

Section 80Section 80ASection 80H

assessment proceedings the A.O noticed that assessee claimed exemption u/s 10B of the Act on the profit and gains from 100% of export oriented unit Etah amounting to Rs.3,47,62,388/- . The assessee claimed that miscellaneous income was pertained to the activity carried out by the said unit

M/S. Hindustan Unilever Ltd, Mumbai vs. The ACIT (TDS)-1(1), Mumbai

In the result, the appeal of the assesse is partly allowed and the appeal of the revenue stand dismissed

ITA 3951/MUM/2008[2000-2001]Status: DisposedITAT Mumbai16 May 2023AY 2000-2001

For Appellant: Nishant Thakkar &For Respondent: Chandip Singh

Section 80Section 80ASection 80H

Dy. Commissioner of Income Tax, Central Circle-1(4), Mumbai vs. M/S Essel Minning & Industries Ltd, Mumbai

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

ITA 3160/MUM/2022[2010-2011]Status: DisposedITAT Mumbai18 Apr 2023AY 2010-2011

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2010-11 Dy. Cit Cc-1(4), M/S Essel Minning & 902, 9Th Floor, Pratishtha Industries Ltd., Vs. Bhavan, Old Cgo Bldg. 18Th Floor, Industry House, (Annexe), M.K. Road, 10, Cama Street, Mumbai-400020. Kolkata-700017. Pan No. Aaaci 1747 H Appellant Respondent Assessee By : Mr. Yogesh Thar/ Ms. Sukanya Jayaram/ Mr. Karan Jain, Ar Revenue By : Mrs. Somogyan Pal, Cit-Dr : Date Of Hearing 02/03/2023 Date Of Pronouncement : 18/04/2023 Order

For Appellant: Mr. Yogesh Thar/For Respondent: Mrs. Somogyan Pal, CIT-DR

Section 10BSection 143(3)Section 153C

domestic tariff are eligible for deduction u/s 10B benefit on in domestic tariff are eligible for deduction u/s 10B benefit on conversion into Export oriented unit, as conversion into Export oriented unit, as mentioned mentioned by CBDT in Circular No. 1/05 dated 06.01.2005 Circular No. 1/05 dated

Picric Ltd vs. ITO Ward 14 (4)

In the result, the appeal of the assessee is allowed with directions contained in para 22 above

ITA 4115/DEL/2007[2004-2005]Status: DisposedITAT Delhi06 Apr 2023AY 2004-2005

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Neeraj Jain,AdvocateFor Respondent: Shri H.K. Chaudhary, CIT(DR)

Section 10BSection 143(1)Section 143(3)Section 80H

guarantee etc., the Ld. AR submitted at the very outset that the said interest income is earned by the assessee from its 100% export oriented unit at Sonipat and the entire FDRs of the value of Rs. 281.11 lac placed with the banks were necessitated by business consideration and partakes ... pointed out that it provides for deduction in respect of profits and gains derived by an 100% export oriented unit from the export of articles or things etc. computed in accordance with sub-section (4) thereof. 9.1 In the written submission filed before