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Please find the attached circular 14/2014 regarding clarification on allowability of deduction under section 10A/10AA on transfer of technical man power in the case of software industry. CBDT decided that the transfer of re-deployment of technical man power from existing unit to a new unit located in SEZ, in the first year of business, shall not be construed as splitting up or reconstruction of an existing business, provided the number of technical man power so transferred as at the end of financial year doesn’t exceed 50% of total technical man power actually engaged. #pdf
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