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2014 (3) TMI 109 - HC - Income TaxInterpretation of Section 10A(2) of the Act - Deduction claimed on income from software exports - Held that:- The decision in Nagesh Chundur v. Assistant Commissioner of Income Tax [2011 (6) TMI 809 - ITAT CHENNAI] followed – Section 10A provides for deduction from the total income of profits derived by an undertaking from the export of articles or things or computer software for a period of ten consecutive years - The tax holiday period commences from the assessment year relevant to the previous year in which the undertaking begins to manufacture or produce such article or thing or computer software - Section 10 (2) prescribes certain conditions on the fulfillment of which the benefit of 10A could be availed - the Revenue’s submission cannot be accepted that it would be giving undue stress and entirely dependent upon the expression “during the previous years relevant to the assessment years” according to Section 10A (2) (i) – Relying upon Circular No.1/2005, benefit of section 10(2) is allowed – Decided against Revenue.
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