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(i) since export of computer software and providing technical services in
connection with development of software are distinguishable from each other, the
profits for providing technical services abroad is to be excluded while computing
deduction under section 10A of the Act;
(ii) section 10A of the Act provides for deduction from the total income only in
respect of profit from export of computer software and profit from rendering of
technical services is not included therein;
(iii) expenses incurred by the assessee in foreign currency for rendering alleged
technical services outside India were to be reduced from export turnover while
computing deduction u/s 10A of the Act.