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"8. We have given our careful consideration to the rival submissions made before us and have perused the orders of authorities below. It is pertinent to note that various objections raised by the A.O. in the assessment order for denying the exemption under section 10A were duly conferred before the Learned Commissioner of Income Tax (Appeals). The assessee-company registered with the Software Technology Parks of India (STPI) and approved as 100% Export oriented unit for Software. In this year, there was a change of name, which is also duly approved by the ROC. Copy of declaration of Software export through data communication link with the company in SOFTEX from the Software Technology Park of India along with purchase orders made by the customers, confirmation of the same, invoice raised to clients and foreign inward remittance certificates from banks confirming receipt of money in the form of foreign exchange were furnished. Certificate regarding qualification of both the Directors was also furnished. The assessee company has made genuine exports, earned foreign exchange, which is not doubted by any other authorities except the A.O. Keeping in view the totality of the facts and circumstances of the case, in our opinion, the Learned Commissioner of Income Tax (Appeals) has given cogent reason indirecting the A.O. To allow th4 exemption under section 10A of the Income Tax Act, 1961. We therefore, inclined to uphold the order of Learned Commissioner of Income Tax (Appeals)."