ACIT, Central Circle-4(1), Kolkata vs. Senco Gold Limited
Parties Involved
Facts Summary
The case involves the appeal by the revenue against the order of the CIT(Appeals)-27, Kolkata, which allowed the claim of deduction under Section 10AA of the Income-tax Act, 1961 by Senco Gold Limited for the assessment year 2010-11. The respondent, Senco Gold Limited, had claimed a deduction of Rs. 2,83,69,865 under Section 10AA for profits derived from the export of gold ornaments manufactured in its Special Economic Zone (SEZ) unit. The Assessing Officer initially disallowed this deduction, which was later allowed by the CIT(Appeals). The revenue argued that the profits included non-qualifying components and that the assessee failed to substantiate its manufacturing activities in the SEZ. The respondent contended that the CIT(Appeals) had correctly allowed the deduction based on consistent findings in previous years and the principle of consistency.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the profits attributed to the SEZ included non-qualifying components and hence not eligible for deduction under Section 10AA.
- 2. Whether the assessee substantiated its manufacturing activities in the SEZ.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
3 precedents cited in this judgement.