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TMI Blog2012 (5) TMI 282X X X X Extracts X X X X X X X X Extracts X X X X ..... the Tribunal holding that the expenditure incurred towards communications expenses as well as travelling, boarding and conveyance expenses is to be reduced from the total turnover while computing deductions under Section 10A of the Act. 2. This question was considered by this Court in the case of CIT v. Tata Elxsi Ltd., [2012] 204 Taxman321/17 taxmann.com 100 and other connected matters which wer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by apportioning the total profits of the business on the basis of turnovers. Apportionment of profits on the basis of turnover was accepted as a method of arriving at export profits. In the case of Section 80HHC, the export profit is to be derived from the total business income of the assessee, whereas in Section 10-A, the export profit is to be derived from the total business of the undertaking. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turnover in the numerator and the denominator cannot be different. Therefore, though there is no definition of the term 'total turnover' in Section 10-A, there is nothing in the said Section to mandate that, what is excluded from the numerator that is export turnover would nevertheless form part of the denominator. Though when a particular word is not defined by the legislature and an ordinary me ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uld have expressly stated so. If they have not chosen to expressly define what the total turnover means, then, when the total turnover includes export turnover, the meaning assigned by the legislature to the export turnover is to be respected and given effect to, while interpreting the total turnover which is inclusive of the export turnover. Therefore the formula for computation of the deduction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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