By Pinky Shah, Sonalee Godbole Chartered Accountants
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Clarification regarding transfer of technical manpower in case of units eligible for deduction u/s. 10A/10AA of the Act applicable to the software industry – Circular No. 14 dated 8th October, 2014
As per the provisions of Section 10A/10AA of the Act read along with Circular no. 12/2014, if upto 20% of technical manpower is transferred from existing unit to new SEZ unit within the first year of commencement of business, it will not be construed as splitting up or reconstruction of an existing business. The upper limit of 20% has been enhanced to 50% of the total technical manpower actually engaged in software development or IT enabled products at the end of the financial year. Alternatively the assessee can also demonstrate that it employed new technical manpower in all its units put together which is at least equal to 50% of the technical manpower of the SEZ unit in the previous year. If either of the two conditions are fulfilled deduction u/s. 10A/10AA of the Act cannot be denied.
A – 12 Point Memorandum has been issued by the CBDT to the assessing officers to ensure a non-adversarial tax regime – F. No. 279/ Misc./52/2014-(ITJ) dated 7th November, 2014 (full text available on www.bcasonline.org)
Erstwhile Bank Term Deposit Scheme,2006 has been revived as Bank Term Deposit (Amendment) Scheme, 2014 effective 13th November, 2014 with the investment limit of Rs. 1,50,000/- u/s. 80C of the Act – Notification No. 63/2014 dated 13th November, 2014
