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2014 (7) TMI 1239 - HC - Income TaxEntitlement to benefit under Section 10A - substantial value addition made before the product is delivered - products manufactured and produced by third parties - assessee is in the business of providing medical transcription facilities - Held that:- Assessee is in the business of transcribing medical transcription. It has outsourced portion of its work as done by the sub contractor is in crude form and cannot be delivered in such form to the overseas customers. The assessee has to process the said product so as to make it marketable. In other words, as rightly pointed out by the appellate authorities value addition has to be done. It is only when that value addition is made, the said product is exported, foreign exchange is earned. The manufacture or production done by the assessee, which is eligible for exemption under Section 10A would be applicable because the transaction done by the sub- contractors in the crude form undergoes a change in the process of the assessee. Therefore, as rightly held that the assessee is entitled to the benefit of Section 10A - Decided in favour of assessee.
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