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2018 (2) TMI 443

Head Note / Extract:
Deduction claimed by the assessee/respondent u/s 10A - foreign inward remittances received were held not to constitute income qualifying for deduction under Section 10A - Held that:- It is quite apparent that customized electronic data or product or service clearly falls within the description of an activity that qualifies for deduction under Section 10A. The lower authorities, we also note this, have relied upon certain other decisions, which take the extended or enlarged meaning of the expression “service” so as to imply not mere manufacture or production of articles or goods but other services. This view is reflected by the Court’s judgment in Commissioner of Income Tax v. Kiran Kapoor (2015 (2) TMI 20 - DELHI HIGH COURT).

Having regard to the nature of the services, and, furthermore, that the STPI clearances were granted for the particular activity i.e. call centre, the Court is of the opinion that there is no error of law, calling for interference.


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