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2011 (3) TMI 3 - AT - Income TaxDeduction under section 80HHE - export of software- refusal to grant deduction - whether provisions contained in paragraph (2) of article 26 will override the distinction made between the resident persons on one hand and the nationals of the U.S.A. and a non-resident on the other - distinction could not have been made - assessee entitled to deduction under section 80HHE on the same footing as it is available to a resident person in India
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