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(iii) "export turnover" means the consideration in respect of export by the undertaking of articles or things or computer software received in, or brought into India by the assessee in convertible foreign exchange in accordance with sub-section (3), but does not include freight, telecommunication charges or insurance attributable to the delivery of the articles or things or computer software outside India or expenses, if any, incurred in foreign exchange in providing the technical services outside India.

Explanation 3.-- For the removal of doubts, it is hereby declared that the profits and gains derived from on site develop-ment 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 semiprecious stones. It may be mentioned that the provisions of sec.10B conferred tax holiday for a period of 5 years initially. Thereafter, the provisions were amended w.e.f. 1/4/1999 and tax holiday period was extended to 10 years and it was also clarified that the units which were entitled for deduction u/s 10B earlier can also claim the benefit of deduction u/s 10B for unexpired period of 10 consecutive assessment years from the commencement of production or manufacture of an article or thing. In the instant case, the respondent-assessee-company had commenced production on 1/10/1996 i.e. in the assessment year 1997-98. It was the claim of the respondent-assessee-company that in terms of sub-sec.(7) of sec.10B, respondent-assessee-company had opted out of the provisions of sec.10B for assessment years 1997-98 and 1998-99 and therefore, the period of 10 consecutive years should be reckoned from assessment year 1999-00 onwards. This contention of the respondent-assessee-company cannot be accepted having regard to the plain provisions of sec.10B, which clearly lay down that period of 10 consecutive years to be reckoned from the assessment year in which production or manufacture of an article or thing was commenced. Same reasoning was followed by the Hon'ble jurisdictional High Court in the case of CIT vs. DSL Software Ltd. (18 taxmann.com