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2014 (1) TMI 1882

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..... ided in M/S. Motorola India Electronics Private Limited [2013 (12) TMI 1702 - KARNATAKA HIGH COURT] profits of the business of the undertaking includes the profits and gains from export of the articles as well as all other incidental incomes derived from the business of the undertaking - what is exempted is not merely the profits and gains from the export of articles but also the income from the b .....

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..... d ineffective, insofar as the following substantial questions of law are concerned: i. Whether the Tribunal was justified in law in relying on the third proviso to sub-Section (1) of Section 10A of the Act, when the conditions stipulated under sub-Section(3) of Section 10A of the Act the export proceeds in convertible foreign exchange is not realised without the stipulated time or within such exte .....

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..... osits can be treated as profits and against as are derived by the assessee from the export of computer software within the meaning of Section 10A? 4. Mr.Suryanarayana, learned counsel appearing for respondent, at the outset, submits that so far as this question IS concerned, it is covered by the judgment of the Division Bench of this court in Commissioner of Income Tax and others V/S M/S. Motorola .....

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