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The order passed by the Tribunal as well as the CIT(A) insofar as it disallows the claim of the appellant with regard to transactions through third parties and inter-unit transfers is hereby quashed and the assessee is held entitled to the benefit of deduction under s. 10B of the Act in respect of third parties and inter unit transfers as well.

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Sec. 10B of Income-tax Act, 1961— Exemption - A narrow and pedantic approach cannot be applied in construing the words "by an undertaking" and restricting the benefit under s. 10B of the Act only in respect of direct export of such goods manufactured by such units. The deemed export by the assessee undertaking even through third party who has exported such goods to foreign country and has fetched foreign currency for India still remains a deemed export in the hands of the assessee undertaking also. - GRANITE MART LIMITED V/s ITO - [2020] 315 CTR 714 (KARN)

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