Manufacturing of new product with new technology at existing place with fresh SEZ approval does not amount to ‘splitting up or reconstruction’

Manufacturing of a new product with a new technology at the same place after taking a fresh approval from SEZ authority does not amount to ‘splitting up or reconstruction’ of an existing business for the purpose of section 10A of the Act. Recently, the Mumbai bench of the Income Tax Appellate Tribunal (the Tribunal) in the case of Portescap India P. Limited Vs. DCIT (ITA No. 1015/Mum/2008) has held that the manufacturing of a new product with a new technology at an existing place after taking a fresh approval from SEZ authorities does not amount to ‘splitting up or reconstruction’ of a...