Gitanjali Exports Corporation Ltd v DCIT ITA Nos.6947&6948/Mum/2011 dated 08-05-2013 (Mum ITAT) Background: Assessee had SEZ units which were engaged in the business of trading in jewellery and diamonds. Assessee claimed the profits therefrom as exempt u/s 10AA in the return of income. The AO disallowed the deduction under section 10AA by observing that the exemption claimed u/s. 10AA is applicable only for manufacturing unit as per the Act, whereas the assessee was involved in trading activities. AO observed that for the purpose of Section 10AA of the Act, manufacture is defined under clause (iii) in Explanation 1 that “(iii) ‘Manufacture’ shall have the same meaning as assigned to it in clause (r) of section 2 of the Special Economic Zones Act 2005”. However, there is no such definition for services.