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2. The assessee herein is an industrial undertaking engaged in Medical Transcription Business. It is seen from the facts narrated that one M/s.KGISL got approval as a 100% EOU in the year 1998 from Software Technology Park of India and started its new business of Medical Transcription during financial year 1999-2000. It is stated that it also had another undertaking engaged in the business of development of software exported outside India. To that end it is stated to have imported machinery, during the assessment year 2000-01 and 2001-02. In respect of business income earned from export, the said undertaking claimed for exemption under Section 10A of the Income Tax Act. In July 2001, the said company transferred the entire undertaking engaged in the export business of Medical Transcription along with all transcriptions contracts, books, records, all rights, all permits, all warranties, including computer software to the assessee company by letter dated 28.5.2001 and 28.6.2001. The transfer was recognised and allowed by Software Technology Park of India. It is a matter of record and not in dispute that vendor company transferred its export obligation to the assessee company. By reason of transfer of the entire business, the employees of the vendor company engaged in Medical Transcription were also transferred and employed by the assessee company. In the background of the income on export, originally, the assessee claimed deduction under Section 10B of the Act. The Officer however rejected the said claim on the ground that when the assessee had filed approval obtained from the Software Technology Park of India for the purpose of Section 10B, the same would not be sufficient to grant the relief. The Assessing Officer further viewed that the assessee had not satisfied the conditions on account of the transfer of business. The Officer further pointed out that transfer related only to machinery. Consequently, the claim could not be sustained. Thus the claim was rejected. However, on the claim under Section 80HHE as an alternative claim, the Officer granted 30% deduction on the profit as allowable under Section 80HHE.