including lifts, Software
and Hardware, Electronic, Electrical works including CCTV
and training of staff for operation and maintenance; only
civil and structural work are excluded ... identify established
practices for apportioning quantitative value of the
technological benefits derived by DLF from the
contribution of Simpark as part of total technological
input
learned counsel for the assessee submits that the aforesaid items are
derived by the STP/SEZ undertakings and were correctly included for computing the
eligible ... deduction under
section 10A is to be computed with reference to working formula in section 10A(4)
wherein the expression 'profit of the business
sections (1) and (1A)],
the profits derived from export of articles or things or
computer software shall be the amount which bears to
the profits ... method provided for arriving at
the profits derived from export of articles or things of computer
software and assessee has followed head count method
only client's
site and the development of computer software in software development
centres of the assessee outside India cannot be construed ... assessee could not prove that
the work carried out at the software development centres is an extension of
software development which took place
Baddi unit and the company has maintained combined
accounts in advanced software for whole of its business.
7.2 The 2nd submission is this that ... working of the profit of Baddi unit. He submitted that the A.O. has pointed out
that correct profit derived form Baddi Unit need
purposes of sub-section (1), the profits derived from
export of articles or things or computer software shall be the amount which
bears ... export
turnover in respect of such articles or things or computer software bears to
the total turnover of the business carried on by the assessee
Data Software Research Co.
Ltd. in I.T.A. No. 2072(Mds)/2006 dated 27.11.2007. Thus, he worked
out the capital gains arising ... Inland Revenue Act
No.10 of 2006 of Sri Lanka, the profits derived from sale of share on
which such share transaction levy was charged
80HHE, 80HHF. For example in sec 80HHC the
mechanism for working out the profits derived from export has
been given in three different situations depending ... eligible for the deduction
should be derived by the assessee from the eligible business. What
are the profits derived from the eligible business is explained
deduction u/s. 10A(1) and s.10B(1) of income derived from an
eligible undertaking is subject to the provisions of the said sections ... respectively, which provide for the manner of working of
the deduction under the said sections. The Revenue has not placed on record any
decision
report discloses "Software development" as
inventory and work-in- progress. It is to be noted that a pure
software services provider would ... development of Software and Software
products since its inception. The company consisting of STPI unit
engaged in Development of Software and Software Products
