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TMI Blog2012 (12) TMI 77X X X X Extracts X X X X X X X X Extracts X X X X ..... e Technology Park of India along with purchase orders made by the customers, confirmation of the same, invoice raised to clients and foreign inward remittance certificates from banks confirming receipt of money in the form of foreign exchange were furnished. Certificate regarding qualification of both the Directors was also furnished. The assessee company has made genuine exports, earned foreign e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee claimed such deduction. The Assessing Officer called upon the assessee to justify such claim. In the assessment order, dated 28.3.05, the assessing Officer detailed various reasons why, according to him, the assessee did not satisfy the conditions for claiming deduction under section 10A of the Act. The assessee carried the issue in appeal. CIT(A) reversed the order of the Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de before us and have perused the orders of authorities below. It is pertinent to note that various objections raised by the A.O. in the assessment order for denying the exemption under section 10A were duly conferred before the Learned Commissioner of Income Tax (Appeals). The assessee-company registered with the Software Technology Parks of India (STPI) and approved as 100% Export oriented unit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come Tax (Appeals) has given cogent reason indirecting the A.O. To allow the exemption under section 10A of the Income Tax Act, 1961. We therefore, inclined to uphold the order of Learned Commissioner of Income Tax (Appeals). To our mind, the entire issue is in the realm of appreciation of facts and the materials on record. CIT(A) and the Tribunal concurrently found that all necessary condition ..... X X X X Extracts X X X X X X X X Extracts X X X X
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