Held that the CBDT has issued a clarification dt. 9th March, 2009 as corrected by Corrigendum No. 178, dt. 8th May, 2009, to clarify that the Board of Approval to grant the approval under S. 14 of Industrial Development and Regulations Act, 1951 has been delegated to Development Commissioner and, therefore, the same shall be considered valid for the purpose of exemption under S. 10B of the Act.-Accordingly the  approvals issued by STPI Directors having Board of Approvals satisfy the conditions of approval as envisaged under Expln. 2(iv) of S. 10B of the Act. The assessee is entitle to deduction. Therefore,  the assessee is entitled for deduction under S.  10B  of the Act. Followed, Dy CIT v. Hitech Infosoft (TTA No 1625/Ahd/2016, dt 3rd Oct, 201 and PCIT v Wizard Enterprises (P) Ltd (2022) 218 DTR  164 (Cal) (HC). The Tribunal also held that  the provisions of S. 80-IA(8) and 80 (A(10) have application only in respect of domestic transactions involving transfer of goods and services of eligible business to any business carried on by the assessee and vice versa. When the provisions of a particular section of the same statute are incorporated in the provisions of another section, all that one has to do is to read the provisions plainly and apply the interpretation, if any ambiguity exists The provisions of S. 80-1A(8) and 80-IA(10) have application only in respect of domestic transactions and the language of the provisions of S.  80 IA(8) and 80-IA(10) is very clear and offer no ambiguity as to scope of operating of said provisions, therefore, the provisions of S. 10B(7) have application only in respect of domestic transactions. On the facts  there is no domestic transactions attracting the provisions of S.  80 IA(8) and 80 (A(10)  The AO has not brought on record any material  to demonstrate that the assessee-company has indulged in an arrangement with its foreign AE to produce the assessee more profits than the profit the assessee might have ordinarily earned out of such business, and the AO has not indicated any material evidence to disclose any such arrangement between the assessee company and its AE Therefore, in the absence of any material demonstrating the existence of any arrangement between the assessee and its foreign AE to produce the assessee more profits than ordinarily what profit the assessee might have expected to arise out of such business, resort to provisions of S.10B(7) cannot be made to restrict the amount of deduction under S 10B and also provisions of S. 10B(7) read with section 80IA have no application in respect of international transactions entered into between the assessee and its foreign AE. Order of CIT(A) is affirmed. (AY. 2010-11,  2011-12)