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(2) This section applies to any undertaking which fulfils all the following conditions, namely :--
(i) it manufactures or produces any articles or things or computer software;

xxxx Explanation 3.--For the removal of doubts, it is hereby declared that the profits and gains derived from on site development of computer software (including services for development of software) outside India shall be deemed to be the profits and gains derived from the export of computer software outside India. Explanation 4.--For the purposes of this section, "manufacture or produce" shall include the cutting and polishing of precious and semi-precious stones."