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2013 (7) TMI 313 - AT - Income TaxDeduction under section 10A - foreign exchange gain - to be treated as Income from Other sources or Profits and Gains of Business - Held that:- The revenue authorities did not look into the account of the assessee, which were placed before them as it is noted that in the year under consideration only two items have been shown as income in the Profit & Loss Account (besides nominal amount of Rs. 283/- as interest), which are export proceeds and exchange difference. It is not the case of the revenue authorities that the conception of exchange difference is not from export proceeds, but from some other source. It could also not be inferred from the Balance Sheet and Profit & Loss Account of the assessee, that exchange gain emanated from any other source or any other funds parked else where. DR, also, could not apprise as to how the exchange gain was detached from export proceeds or how the decision of Changepond Technologies (P) Limited. Vs ACIT [2008 (2) TMI 486 - ITAT MADRAS-A] could not be relied upon. It has also not been shown by the revenue authorities that the export proceeds were not received within the stipulated period, i.e. the last day of the previous year. Thus the gain recorded by the assessee on receipts of foreign exchange as export proceeds are extricably linked and are, therefore, eligible for exemption under section 10A of the Income Tax Act. In favour of assessee.
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