Whether the benefit of deduction under Section 10A can be extended to inter-state sales made to another industrial unit in a SEZ, payment in respect of which is received in Indian rupees?

Commissioner of Income Tax, Cochin Vs Electronic Controls & Discharge Systems (P) Ltd [2011] 13 Taxmann.com 193 (Kerala High Court)- Benefit of deduction under Section 10A is not available in respect of sales made to a unit in Special Economic Zone even though such sales are considered as ‘deemed exports’ under the provisions of the Special Economic Zones Act, 2005.

The provisions in Section 10A are comprehensive and exhaustive and that the mandatory conditions of Section 10A (3) have to be satisfied

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