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- Alternatively, the CIT (A) was not justified in failing to appreciate that the assessee was engaged in development and export of computer software and not in providing technical services;

(4) That the CIT (A) was not justified in holding that the loss from Telecom Division of Rs.5,10,445/- should be reduced from the profits of the eligible under- taking before computing relief u/s 10A of the Act;

5.5. The third ground is that the CIT (A) was not justified in holding that the foreign travel expenditure should be reduced from the export turnover.

5.5.1. Alternatively, it was contended that the CIT (A) was not justified in failing to appreciate that the assessee was engaged in development and export of computer software and not in providing technical services.

5.5.2. It is an undisputed fact that the assessee was engaged in development and export of computer software and not in providing technical services. Therefore, the foreign travel expenses incurred could not have been reduced from the export turnover on the basis that the same was incurred in providing the technical services outside India.