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(ii) foreign currency expenses incurred onsite for development of computer software be not regarded as expenses incurred for providing technical services outside India;
(iii) in the alternative and without prejudice, if foreign currency expenses incurred onsite for development of computer software be reduced from export turnover, the same be also reduced from total turnover in the process of computation of deduction u/s 10B;
(iii) foreign currency expenses incurred onsite for development of computer software be not regarded as expended incurred for providing technical services outside India;
(iv) in the alternative and without prejudice, if foreign currency expenses incurred onsite for development of computer software be reduced from export turnover, the same be also reduced from total turnover in the process of computation of deduction u/s 10B;
(v) foreign currency expenses incurred onsite for development of computer software be not regarded as expenses incurred for providing technical services outside India;
(vi) in the alternative and without prejudice, if telecommunication charges of Rs.7,33,288/- and foreign currency expenses incurred onsite for development of computer software be reduced from export turnover, the same be also reduced from total turnover in the process of computation of deduction u/s 10B;
4.10 In the following decisions, it has been held that development of computer software does not amount to rendering of technical services and accordingly expenses incurred in foreign currency should not be reduced from export turnover in the process of computing deduction under section 10B /10B.
Zylog Systems Ltd v ITO [2011] 7 ITR (Trib) 348 Chennai SB;