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19. We heard the parties and perused the material on record. Before proceeding on merits, we will look at the relevant provisions of section 10AA, which reads as below:-

"10AA. **** (7) For the purposes of sub-section (1), the profits derived from the export of articles or things or services (including computer software) shall be the amount which bears to the profits of the business of the undertaking, being the Unit, the same proportion as the export turnover in respect of such articles or things or services bears to the total turnover of the business carried on by the undertaking: