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5.2 The assessee further submitted that being a 100% EOU it has to file quarterly and annual reports of sales details with STPI in Software Export Declaration (SOFTEX) Form. After verifying and examining the details, the STPI grants certificate with regard to export, data link and price structure. The STPI while granting certificate has not raised any objection with regard to price structure. Accordingly the assessee contended in such circumstances the provision of section 80IA(10) A.Y. 2008-09 cannot be invoked. The assessee in this regard placed its reliance on the order of Hon'ble Chennai ITAT in case of Bebo Technologies Pvt Ltd vs. JCIT 51 SOT 87.