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However the units in SEZs will continue to follow the GR/PP/SOFTEX export procedure outlined in part B of Annexure A.P.(DIR Series) Circular No. 12 dt. September 9, 2000 as amended from time to time". The AR further submitted that the AO's observations that the circular is only prospective would be out of place. The AR has furnished complete list of export proceeds which has been denied by the revenue authorities. The AR referred to the case of CIT V/s Morgan Stanley Advantage Services Pvt. Ltd., reported in 339 ITR 291, 294, wherein the Hon'ble Bombay High Court has held, "the extension has been granted in substance and therefore, the benefit of section 10A has to be allowed to the assessee on the ground that the extension is deemed to have been granted". The AR submitted that in the case of the assessee, it is the competent authority who is issuing the circular for the projects in the SEZs, where, now, according to the circular there is no time limit for realization of export proceeds. The AR therefore, submitted that the revenue authorities were wrong to exclude the unrealized export proceeds for computation of the exemption.