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2014 (7) TMI 1132 - AT - Income TaxDeduction under section 10A denied - as per AO or the assessment year 2009-10, the assessee itself did not consider the receivables of ₹ 37,75,28,906 for the purpose of claim of deduction under section 10A, hence, granting of deduction u/s 10A on such amount does not arise - CIT(A) allowed the claim - Held that:- The issue in the present case before us is that the gross bills raised by the assessee are paid by the foreign clients in convertible foreign exchange and then only the assessee makes the payment to the foreign client from the same amount which in accounting terms is known as setting off or netting off. Since the same is done with the approval of the Reserve Bank of India the assessee is only to claim deduction under section 10A of the Act on the total amount of gross bills raised by the assessee as the same was received in convertible foreign exchange. The issue in the present appeal is similar to that of J. B. Boda and Co. Pvt. Ltd. [1996 (10) TMI 70 - SUPREME Court] and, therefore, we find no infirmity in the order of the Commissioner of Income-tax (Appeals) in following the judgment of the hon'ble Supreme Court and the same is upheld. - Decided in favour of assessee.
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