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(a) Wipro Systems [7 STP units situated at Bangalore (5) and Hyderabad (2)]
(b) Global R & D [3 STP units at Bangalore]
(c) E-Commerce (part of STP, Lavelle Road, Bangalore, coming under Wipro Systems] 3.1 As stated by the AO, the assessee had filed detailed P&L a/c statements for each of the sub-division and in turn for each of the STP unit and consolidated the total claim of exemption under Section 10A. The total software exports aggregated to Rs. 3,91,44,28,081. This turnover included miscellaneous income of Rs. 1,47,22,733. The total expenditure accounted is Rs. 289.23 crores. The AO called for and examined the details of group-wise, division-wise and sub-division-wise P&L a/cs and expenditure details. He also called for softex forms filed with STPI authorities and examined the same. The AO obtained particulars of sales break-up, country-wise as well as customer-wise. He has also verified the details of other income and expenditure."

5.4 The three sub-divisions narrated supra comprise the total software exports made by the company to the tune of Rs. 3,91,44,28,081. This turnover also includes miscellaneous income of Rs. 1,47,22,733. The expenditure booked is Rs. 289.23 crores leaving a profit of Rs. 102.21 crores claimed as exempt under Section 10A. On making further adjustments to this profit, an amount of 102.32 crores was claimed as exempt in the tax return vide Annex. 111, referred supra.

5.5 The software exports narrated supra are in turn part and parcel of the turnover of 'Infotech group'. The assessee-company, M/s Wipro Ltd., comprises of five such groups and the final statements of accounts are consolidation of accounts of all these groups. Group-wise, division-wise and sub-division-wise P&L a/c and expenditure details and income details were called for and examined. The softex forms filed with STPI authorities were also called for and were examined. The sales break-up was obtained country-wise as well as customer-wise. The details of other income as well as expenditure were obtained. On perusal of all such details, the exempted income under Section 10A is now assessed as under : "

(a) Wipro Systems [7 STP units situated at Bangalore (5) and Hyderabad (2)]
(b) Global R & D (3 STP units at Bangalore)
(c) E-Commerce (part of STP, Lavelle Road, Bangalore, coming under Wipro Systems) 3.1 As stated by the AO, the assessee had filed detailed P&L a/c statements for each of the sub-divisions and in turn for each of the STP units and consolidated the total claim of exemption under Section 10A. The total software exports aggregated to Rs. (3,91,44,28,081. This turnover included miscellaneous income of Rs. 1,47,22,733. The total expenditure accounted is Rs. 289.23 crores. The AO called for and examined the details of group-wise, division-wise and subdivision-wise P&L a/c and expenditure details. He also called for softex forms filed with STPI authorities and examined the same. The AO obtained particulars of sales break-up, country-wise as well as customer-wise. He has also verified the details of other income and expenditure."