In the return of Income for A.Y. 2011-12, the assessee company claimed deduction u/s.10AA for a sum of Rs.47,19,678/-. The assessee claimed deduction under section 10A for ten consecutive assessment years from AY 2000-01 till AY 2010-11 and in the A.Y 2011-12 the assessee claimed deduction under section 10AA .AO held that the assessee is not eligible for deduction u/s.10AA at all since, as per section 10AA(1), the unit is eligible for deduction, only if the unit begins to manufacture or produce articles or things or provide any services during the previous year relevant to A.Y. 2006-07 onwards. In the present case the assessee has began manufacture in previous year relevant to A.Y. 2001-02. Therefore, the assessee is not eligible to claim deduction under section 10AA. CIT (A) confirmed the order of the AO . On appeal the Appellate  Tribunal held that assessee not having exhausted deduction under S. 10A for ten consecutive assessment years on date of introduction of S.  10AA as was available to him under S.  10A on commencement of SEZ Act, 2005 will be entitled for additional period of deduction for five years as is allowed to SEZ units by provisions of S. 10AA(1)(ii), subject to fulfilment of other conditions.  (AY. 2011-12)