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2020 (8) TMI 769 - HC - Income TaxComputation of deduction u/s 10B - Whether expenditure incurred in foreign currency reduced from export turnover has to be reduced from total turnover - Tribunal held that expenditure in foreign exchange reduced from export turnover has to be reduced from total turnover also - brought forward losses and unabsorbed depreciation cannot be set off against the profits for computing deduction under Section 10B - HELD THAT:- Revenue fairly submitted that first substantial question of law has been answered against the revenue in 'COMMISSIONER OF INCOME-TAX VS. HCL TECHNOLOGIES LTD.' 2018 (5) TMI 357 - SUPREME COURT whereas the second substantial question of law has also been answered against the revenue by Supreme Court in 'COMMISSIONER OF INCOME-TAX VS. YOKOGAWA INDIA LTD. 2016 (12) TMI 881 - SUPREME COURT Expenditure incurred towards acquisition of software - Whether expenditure incurred towards acquisition of software is only a right to use for a limited period and no property or right of permanent character is being acquired and hence expenditure incurred is capital in nature? - HELD THAT:- The expenses are incurred for application of software, the third substantial question of law is also answered against the revenue by a division bench of this court in 'COMMISSIONER OF INCOME-TAX, BANGALORE VS. ROBERT BOSCH INDIA LTD. 2014 (6) TMI 906 - KARNATAKA HIGH COURT
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