Assessee is a trading firm, engaged in business of importing diamonds for purpose of re-export after sorting and grading from SEZ Unit which claimed deduction u/s. 10A of the Act. The AO disallowed the claim on ground that no manufacturing activity was undertaken by hence not eligible to claim the exemption. On appeal the Tribunal held that in absence of definition of services under section 10AA, Services as   defined under SEZ Act and rules framed thereunder would be relevant. As per definition of Services under Rule 76 of SEZ Rules, trading activity also comes within its ambit, therefore, import of diamonds for re-export would be in nature of  Services, accordingly, assessee would be entitled to deduction. (AY. 2012-13)