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2. In the assessment order, it is mentioned that the assessee company is engaged in the activity of trading of generic software, and providing customized software development services for domestic and US market, through its two units situated in Software Technology Park, Gurgaon. The assessee claimed exemption under Section 10A of the Act. This section is applicable to an undertaking if the sale proceeds of the articles, things or computer software, exported out of India, is received in or brought into India in convertible foreign exchange within a period of six months from the end of previous year, or within such further period as the competent authority may allow. It is further mentioned that the details of realization of export proceeds, in respect of which the exemption was claimed, were furnished. The details of expenses incurred in foreign exchange for providing technical services were also furnished. On examination of these details, it was found that the assessee incurred expenditure in foreign exchange in sending software professionals abroad as per the agreements with the foreign constituents. Such expenses in both the units amounted to Rs. 1,82,610 in Indian rupees. The assessing officer was of the view that these expenses are required to be deducted from the export turnover for the purpose of computing deduction under Section 10A. It is also mentioned that while total receipts in respect of unit No. 1 and unit No. 2 were Rs. 14.52 crores and Rs. 3.13 crores, the total turnover of these units was taken at Rs. 5.62 crores and Rs. 2.30 crores respectively. It was explained that in order to execute the software development orders, the assessee recruited software professionals in the USA. These professionals were paid remuneration on the basis of man-hour or man-month of work done by them. These payments were made out of the sale proceeds received abroad. That did not mean that the export turnover had to be decreased by the amount of remuneration paid to the foreign professionals in the USA. The assessing officer pointed out that while Section 10A specifically defined the term "export turnover" it did not define the term "total turnover". The total turnover- is nothing but a sum of domestic turnover and export turnover. Further, he was of the view that the total turnover includes that part of the export turnover also which has not been received in or brought into India in convertible foreign exchange. Thus, while computing the total turnover, payments made to foreign professionals in USA could not have been excluded. Accordingly he took the total turnover by taking into account the payments made to foreign professionals in the USA.