Section
10B defines export turnover as under:
"(iii) “export turnover” means the consideration in respect
of export (by the undertaking) of articles or things ... export
turnover” as defined in clause (iii) above would go to
show that “export turnover” of computer software means
consideration received in respect of export
makes a distinction between
technical services rendered in connection with export
of computer software and export of technical services
for the purpose of development ... services cannot be excluded in computing
the export turnover as it forms part of the export
turnover. In the instant case as is clear from
turnover and the Export turnover while computing
deduction under Section 10A especially when the explanation
clearly stipulates that in the case of Export turnover alone ... turnover and the Export turnover while computing
deduction under Section 10A especially when the explanation
clearly stipulates that in the case of Export turnover alone
export turnover' must also be excluded from 'total
turnover', since one of the components of 'total
turnover' is export turnover ... arrive at the profit from
export business, expenses excluded from export
turnover have to be excluded from total turnover
also. Otherwise, any other interpretation makes
Date
turnover as well as from
export turnover for computation of deduction
u/s.10A whereas such exclusion is permitted to
arrive at export turnover only ... export
turnover' must also be excluded from 'total
turnover', since one of the components of 'total
turnover' is export turnover
term 'total turnover', Explanation 2(iv) defines 'export turnover' in the
following terms:
'(iv) "export turnover" means ... Export turnover as defined in Explanation 2
(IV) of Section 10A of IT Act
Export Profit = total Profit _____________________________________
of the Business X Export turnover
export turnover' must
also be excluded from 'total turnover', since one of
the components of 'total turnover' is export turnover ... arrive at the profit from
export business, expenses excluded from export
turnover have to be excluded from total turnover
also. Otherwise, any other interpretation makes
export
turnover' must also be excluded from 'total
turnover', since one of the components of 'total
turnover' is export turnover ... arrive at the profit from
export business, expenses excluded from export
turnover have to be excluded from total turnover
also. Otherwise, any other interpretation makes
total turnover,
as clause (iv) of the Explanation to section 10A
provides that such expenses have to be
reduced only from the export turnover ... incurred in foreign
currency for rendering technical services
outside India both from the export turnover
and the total turnover when there is no
provision
traveling expenses
incurred in foreign currency for providing
technical services outside India in export turnover
as well as from total turnover by relying upon ... excluding comparables such as Accentia
Technologies Ltd, Cosmic Global Ltd and Eclerx
Services as comparables by following its earlier
decisions even though the said companies
