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...We accordingly hold that the appellant company was not involved in the business of providing technical services outside India in connection with the development of computer software. We therefore direct that in computing the figures of export turnover and total turnover relevant for the application of the formula in Sub-section 3 of Section 80HHE, no exclusion be made of any expenditure incurred in foreign currency other than those already done by the assessee company.

A cursory perusal of the same would indicate that in the case relied on by the assessee, cited supra, assessee did not involve in the business of providing technical services outside India in connection with development of computer software but only completed export obligation. The learned Commissioner (Appeals), considering this aspect rightly rejected the contention of the assessee. In the present case, there are materials to show that the expenditure in foreign currency is related to technical services rendered outside India by the assessee in connection with development of computer software to the customers outside India.