The claim of deduction u/s 10AA of the Act was denied on the ground that the assessee was not engaged in manufacture or production of articles or goods. The definition of service as provided in clause 2(z) of the Special Economic Zones Act, 2005 in the opinion of the Assessing Officer could not be imported into section 10AA and therefore, the deduction as claimed by the assessee would not be allowable. The Commissioner (Appeals) allowed the claim of the assessee. On appeal the Tribunal held that virtue of section 51 of the 2005 Act, the provisions of the 2005 Act and the Rules will have overriding effect over the provisions contained in any other Act. Thus, the provisions of the 2005 Act would be applicable and since the trading was covered by services and services include trading under the 2005 Act. Therefore, trading done by the assessee was a service and, therefore, deduction under section 10AA was allowable. (AY.2014-15)