This compilation indexes twelve income-tax rulings — eleven from various benches of the Income Tax Appellate Tribunal and one from the Gujarat High Court — each of which engages Section 10A of the Income Tax Act, 1961, as a cited provision. The rulings span the period June–September 2026 and arise from a cross-section of taxpayer profiles: cooperative societies, Hindu Undivided Families, IT and BPO majors, jewellery exporters, and software firms operating out of Special Economic Zones. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a rapid-reference index of recent Section 10A litigation activity.

Research index only. This page catalogues publicly available judicial orders for research and informational purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation to take or refrain from any action. Readers must consult the full text of each judgment and qualified legal counsel before relying on any ruling.

The statutory framework in one paragraph

Section 10A of the Income Tax Act, 1961 provided a profit-linked deduction to undertakings established in Free Trade Zones, Electronic Hardware Technology Parks, Software Technology Parks, and Special Economic Zones, in respect of profits derived from the export of articles, computer software, or other notified goods or services. The deduction, originally available for a period of ten consecutive assessment years beginning from the year in which the undertaking began manufacturing or production, was subject to a range of conditions including filing of the return of income within the due date under Section 139, maintenance of separate books of account for the eligible unit, and the receipt of export proceeds in convertible foreign exchange within the prescribed period. Section 10A was sunset for new units after certain dates and was, in certain respects, succeeded by Section 10AA for SEZ units; however, Section 10A continues to generate live litigation for assessment years falling within its operative window.

The 12 rulings

1. Bhagwan Shree Agrasen Nagari Sahakari vs ITO, Ward 9(3), Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 10 September 2026
Sections engaged: 10A, 139, 142, 143(1), 143(1)(v), 154, 80, 80A, 80P(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.2480/PUN/2026) was filed by the assessee against the order passed under Section 250 for AY 2022-23 dated 20.03.2026, itself arising from a rectification order passed under Section 154 for AY 2022-23 on 29.08.2025. The assessee was not represented at the hearing; the matter proceeded on the basis of the available record and submissions of the Revenue representative.

2. Kishore Kewalram Zamtani, Huf,Nagpur vs ITO Ward-3(4), Nagpur

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 10 September 2026
Sections engaged: 10, 10A, 115B, 139, 16, 23, 24, 32, 32A, 33A, 35, 35A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.802/NAG/2025) for AY 2023-24 was directed against the order dated 10.10.2025 framed by the Addl/JCIT(A), Jodhpur/(NFAC), arising out of a rectification order dated 25.07.2025 passed under Section 154. The assessee, a Hindu Undivided Family, had contended that the Centralized Processing Centre denied the benefit of the option exercised for paying tax under the new tax regime; none appeared on behalf of the assessee at the hearing.

3. Genpact Infrastructure (Hyderabad) vs ITO, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 9 September 2026
Sections engaged: 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.2055/Del/2015) for AY 2009-10 was filed by the assessee — Genpact Infrastructure (Hyderabad) Private Limited, now merged with Genpact India — against the Income Tax Officer, Ward 12(3), New Delhi. Per the source preview, one of the grounds raised by the assessee was that the learned CIT(A)/AO had grossly erred on facts and in law by disregarding judicial pronouncements in India while undertaking the transfer pricing adjustment.

4. Dell International Services India vs The Joint Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 4 September 2026
Sections engaged: 10A, 143(3), 154(3), 250, 263, 36(1)(va)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 287/BANG/2026) for AY 2011-12 was filed by Dell International Services India Private Limited before the Bangalore Bench. The source preview confirms the matter proceeded before the Bench with hearing concluded on 23 June 2026 and pronouncement on 4 September 2026; the substantive grounds, engaging multiple provisions including Section 10A, Section 143(3), Section 154(3), Section 250, Section 263, and Section 36(1)(va), are noted from the sections cited in the record.

5. ACIT, Rajkot vs Crystal Global Industries, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 31 August 2026
Sections engaged: 10A, 10B, 10C, 80, 801C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 508, 537 & 538/Rjt/2025) covered AYs 2011-12, 2013-14, and 2014-15, with cross-appeals by both the Revenue (ACIT) and the assessee (Crystal Global Industries). Per the source preview, the Bench indicated it would first adjudicate the Revenue's appeals in ITA Nos. 537 and 538/RJT/2025 for AYs 2013-14 and 2014-15; the matter involved provisions relating to export-linked deductions under Section 10A, 10B, and 10C.

6. Shree Ulka Llp ,Mumbai vs ACIT, Central Circle 1, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 27 August 2026
Sections engaged: 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 9233 & 9234/Mum/2025) for AYs 2021-22 and 2022-23 were filed by Shree Ulka LLP, a limited liability partnership engaged in production, processing, and preservation of fish and fish products from its unit situated in the Mangalore Special Economic Zone, as indicated in the source preview. The assessee filed revised grounds of appeal, which the Bench admitted as concise and arising from issues already contested in the original grounds.

7. Joint Commissioner Of Income Tax vs Gaurav Sharma, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 25 August 2026
Sections engaged: 10A, 111A, 112, 112A, 115, 115B, 139, 16, 23, 24, 250, 32
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised ITA No. 698/JPR/2026 filed by the Revenue and a Cross Objection (CO No. 11/JPR/2026) filed by the assessee Gaurav Sharma, both pertaining to AY 2024-25. The source preview indicates that the order was pronounced on 25 August 2026, with multiple income-tax provisions cited across the record; the proceeding involved both the Revenue's appeal and the assessee's cross objection arising out of the same ITA.

8. Tech Mahindra Ltd,Mumbai vs DCIT Cir 2(3), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 24 August 2026
Sections engaged: 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 7487/MUM/2012) for AY 2008-09 was filed by Tech Mahindra Ltd before the Mumbai Bench. The source preview includes a computation table reflecting a deduction under Section 10A of Rs. 8,68,11,17,341/- as claimed in the revised business income computation, alongside foreign currency income figures across multiple financial years, indicating the dispute involved the quantum of the Section 10A deduction.

9. Adani Exports vs Income Tax Officer - Ward - 5 (2) (2)

Bench: Gujarat High Court
Date: 5 August 2026
Sections engaged: 148, 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/Special Civil Application No. 3597 of 2016) challenged a notice dated 27.03.2015 issued under Section 148 seeking to reopen the petitioner's income tax assessment for AY 2010-11. Per the source preview, the petitioner is a partnership firm engaged in manufacturing and exporting gold jewellery from the Special Economic Zone, Sachin, Surat; Section 10A is cited as an engaged provision in the record alongside Section 148.

10. Intersoft Data Labs And Solution vs Jcit Range 26, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 31 July 2026
Sections engaged: 10A, 145
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.3086/Del/2026) for AY 2017-18 was filed by Intersoft Data Labs and Solution Private Limited. Per the source preview, the assessee had filed its return of income dated 30.11.2017 declaring total income of Rs.5,18,29,080/- and had claimed a deduction under Section 10AA of Rs.2,32,47,897/- from its unit in SEZ Mohali; the case was selected for scrutiny with notices duly issued and served, and the AO passed an assessment order thereafter.

11. Dewsoft Overseas Pvt Ltd,Delhi vs ACIT, Circle 7(2), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 July 2026
Sections engaged: 10A, 68
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involved a batch of consolidated appeals (ITAs No.3010 to 3023/Del/2026) covering multiple assessment years including AYs 2010-11, 2013-14, 2015-16, 2016-17, 2019-20, and 2020-21. Per the source preview, it was noted that the present appeal had been belatedly filed with a delay of 174 days beyond the period of limitation, for which the assessee filed an application for condonation of the said delay; the Bench passed a consolidated order given that the facts were identical across the batch.

12. Imperial Jewels,Mumbai vs DCIT-24(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 June 2026
Sections engaged: 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 5941/MUM/2025) for AY 2022-23 was filed by Imperial Jewels, a unit located at SEEPZ SEZ, Andheri (East), Mumbai, against the order dated 29.08.2025 passed by NFAC, Delhi. The source preview identifies the assessee as a jewellery exporter operating out of an SEZ unit, with the appeal arising from the CIT(A)/NFAC order for AY 2022-23.

Patterns across these 12 rulings

SEZ-based export units are a recurring profile. Multiple cases in this compilation — including those involving a fish-processing LLP in the Mangalore SEZ, a gold jewellery exporter in the Sachin SEZ, and a jewellery unit in SEEPZ — indicate that SEZ-based exporters across diverse sectors continue to generate active Section 10A litigation.
Rectification orders under Section 154 as a trigger. At least two cases in this set (case indices 1 and 2) arise not from original assessments but from rectification orders passed under Section 154, with the appellants challenging the downstream first-appellate orders. This reflects a pattern of Section 10A disputes surfacing at the rectification stage.
Long-pendency appeals are still being heard. Several rulings in this compilation relate to assessment years well over a decade old — including AY 2008-09 (case 8), AY 2009-10 (case 3), and AY 2010-11 (case 9) — underscoring that Section 10A deduction disputes frequently take many years to reach final adjudication at the appellate level.
Transfer pricing adjustments intersecting with Section 10A. The Genpact Infrastructure matter (case 3) specifically raises the ground that the AO/CIT(A) erred by disregarding judicial precedents while undertaking a transfer pricing adjustment, indicating that TP adjustments affecting the quantum of Section 10A-eligible profits remain a live issue.
Delay in filing and procedural admissibility. The Dewsoft Overseas matter (case 11) highlights that delay-condonation applications accompany a portion of Section 10A appeals, reflecting the practical challenge of maintaining limitation compliance across multi-year batches of consolidated appeals.

How to use this compilation

This index is a starting point for locating recent orders that cite Section 10A of the Income Tax Act, 1961. Each entry supplies the tribunal/court, bench, date of pronouncement, ITA or petition number (where visible in the source preview), and the sections cited in the record. Because the source data available to this index does not include the full reasoned operative portion of every order, researchers should retrieve and read the complete judgment text before drawing any conclusions about the ratio, holding, or precedential value of any ruling. Full judgment texts are available on the Income Tax Appellate Tribunal's official website, the respective High Court portals, and indiankanoon.org.

Before relying on any ruling listed here, researchers should verify: (a) whether the order has been challenged before a higher forum and whether a stay, reversal, or modification is in force; (b) whether the CBDT has issued a circular, instruction, or notification that affects the statutory provision or the legal position affirmed in the ruling; and (c) whether subsequent Supreme Court or High Court decisions have altered the legal landscape on the specific issue. Case law databases, including this one, reflect a point-in-time snapshot and cannot substitute for a current legal due diligence exercise.

Researchers using this compilation for advisory, litigation, or compliance work are further reminded that the outcome field for all twelve rulings is recorded as "Outcome not specified in source" — meaning the dispositive direction (allow, dismiss, partly allow, remand) could not be confirmed from the available source preview. No inference about the merits or result of any of these proceedings should be drawn from their inclusion in this index.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 10A Income Tax: 12 ITAT & HC Rulings Index (2026)