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3. These grounds were considered by the Tribunal in
paragraphs 10 to 14 of their order dated 15.2.2008. The Tribunal
held that the technical services provided outside India by the
assessee was for development of computer software which was
also a part of the requirement of the assessee in development of
software as per the requirements and specifications of the clients.
Therefore, the Tribunal held that the said activity of the assessee
comes under the definition of on site development of computer
software including services for development of software outside
India as provided in Explanation 3 to sub-sec.(8) of sec.10A of the
Act. Accordingly, the Tribunal held that the expenses incurred on
salaries, travelling and other perquisites shall be included in the
export turnover of the assessee."