TMI Blog2011 (4) TMI 722X X X X Extracts X X X X X X X X Extracts X X X X ..... n u/s 10A on the plea that it was not derived from export business - On the other hand, the assessee contended that these receipts were derived from export of computer software - The Tribunal found that the CIT(A) had not decided the nature of the receipts - Therefore , Tribunal has referred the matter back to the CIT(A) for deciding the nature of receipts so as to find out whether the same are de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income-tax return for the assessment year 2005-06, the assessee declared 'NIL' income and claimed deduction under section 10A of the Act as a whole. The Assessing Officer, during the course of scrutiny assessment, found that various expenditure has been incurred in foreign currency which included 'speed pay' and 'ASP expenses'. The assessee had received payments, inter alia, on account of spe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and ASP fees was not to be included for the purpose of computing deduction under section 10A on the plea that it was not derived from export business. On the other hand, the assessee contended that these receipts were derived from export of computer software. The Tribunal found that the CIT(A) had not decided the nature of the receipts. 4. In these circumstances, the Tribunal has referred the m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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