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2012 (11) TMI 848 - HC - Income TaxDeduction u/s 80O or 80HHE - development or production of computer software - Manpower deputation to foreign customers – Export of software – Technical service rendered outside India - Also utilised for rendering services in computer software even in India – Held that:- When the specific provision u/s 80HHE is concerned about technical services rendered in connection with software development, we do not approve of the line of reasoning of the Tribunal. - one cannot make Section 80-O as an alternate to an allowability of the deduction under Section 80HHE for the purpose of better tax deduction. - Decided in favor of revenue.
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