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(iii) ―export turnover‖ means the consideration in respect of export 3by the undertaking of articles or things or computer software received in, or brought into India by the assessee in convertible foreign exchange in accordance with sub- section (3), but does not include freight, telecommunication charges or insurance attributable to the delivery of the articles or things or computer software outside India or expenses, if any, incurred in foreign exchange in providing the technical services outside India.

Explanation 3.--For the removal of doubts, it is hereby declared that the profits and gains derived from on site development of computer software (including services for development of software) outside India shall be deemed to be the profits and gains derived from the export of computer software outside India.

Explanation 4.--For the purposes of this section, ―manufacture or produce‖ shall include the cutting and polishing of precious and semiprecious stones.‖ From the perusal of aforesaid section, it is apparent that this section provides that any profits and gains derived by an assessee from a 100% EOU shall not be included in the total income of the assessee. This provision applies to any undertaking which manufactures or produces any article or thing. Explanation