TMI Blog2014 (7) TMI 1239X X X X Extracts X X X X X X X X Extracts X X X X ..... rightly pointed out by the appellate authorities value addition has to be done. It is only when that value addition is made, the said product is exported, foreign exchange is earned. The manufacture or production done by the assessee, which is eligible for exemption under Section 10A would be applicable because the transaction done by the sub- contractors in the crude form undergoes a change in the process of the assessee. Therefore, as rightly held that the assessee is entitled to the benefit of Section 10A - Decided in favour of assessee. - ITA No.1068 OF 2008 c/w ITA.No.108/2010 - - - Dated:- 7-7-2014 - HON'BLE MR. JUSTICE N. KUMAR AND THE HON BLE MR. JUSTICE B MANOHAR For the Appellant : Sri K V Aravind, Advocate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de to sub contractor s comes to ₹ 53,95,533/-. A payment of ₹ 22,75,381 /- was made to Target Transcriptions (P) Limited who carried out the activity in the premises of the assessee. The balance payment of ₹ 31,20,152/- was made to Xen Call Centre and Infy Communications (P) Limited , who carried out the work outside. Therefore, only payment of ₹ 31,20,152/- was made to sub- contractors who carried out the work outside the premises. The transcription work done by sub- contractors is in crude form and cannot be delivered in such form to the overseas customers. Subsequently, processing is done which involves preparation of preliminary/basic medical records, proofing/editing etc. To ensure quality a number of chec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion before the product is delivered. Therefore, the appellate authority was justified in extending the benefit of Section 10A to the assessee. Accordingly, the appeal came to be dismissed. Aggrieved by the said order, the revenue is in appeal. 3. The substantial questions of law which were framed at the time of admitting these appeals are a s under:- (a)Whether the appellate authorities were correct in holding that assessee would be entitled to claim deduction under Section 10A of the Act in respect of products manufactured and produced by third parties as there was value addition to the same by relying on the Board circular No.1/05 dated 6.1.2005 which was applicable to provisions of Section 10B of the Act? (b)Whether the appel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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