Tax Deduction Dispute: Export Turnover Calculations Refined, Software Services Differentiated Under Sections 10A, 80HHE, and 80M

HC ruled on computational aspects of tax deductions under Sections 10A, 80HHE, and 80M. The court partially favored the appellant, holding that export turnover calculations must exclude foreign currency expenditures for on-site software development. Technical services and software manufacturing were distinguished. Deductions under Sections 10A and 80HHE were restricted to 90% and 50% respectively for AY 2003-2004. The court directed the Assessing Officer to recompute deductions after verifying actual software exports and technical services. Most substantial questions were answered against the appellant, with specific questions related to export turnover and dividend income being resolved against the appellant's claims. .....

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