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| The Tax Publishers2020 TaxPub(DT) 3732 (Ahd-Trib) INCOME TAX ACT, 1961
Section 10AA
Assessee dealing in fuel oil and High Speed Diesel, also setting up and operating facilities in connection with planting, storage, delivery and other logistic operations for bunkering business, was duly engaged in manufacturing in terms of Special Economic Zone Act, 2005 and was, therefore, eligible for deduction/exemption under section 10AA.
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Deduction under section 10AA - Allowability - Assessee dealing in fuel oil and High Speed Diesel and setting up and operating facilities in connection with bunkering business -
Assessee company dealing in fuel oil and High Speed Diesel, also setting up and operating facilities in connection with planting, storage, delivery and other logistic operations for bunkering business, registered as a'SEZ' Unit claimed deduction under section 10AA. AO disallowed deduction under section 10AA on the ground that assessee had not manufactured and/or produced articles or things or provided any services from its SEZ Unit. Held: Assessee imported various fuel oil in bulk which were blended in the tanks hired by it at Mundra Port. Also, assessee hired tanks which were well equipped for carrying out blending activities covered within the meaning of manufacturing as provided under Special Economic Zone Act, 2005 which have overriding effect on the Income Tax Act. Accordingly, assessee was eligible for deduction/exemption under section 10AA.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2012-13
IN THE ITAT, AHMEDABAD BENCH
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