TMI Blog2015 (8) TMI 662X X X X Extracts X X X X X X X X Extracts X X X X ..... in foreign exchange for providing technical services outside India, those were not included in the export turnover - Held that:- Explanation 2 (iv) to Section 10A of the Act provides that freight, telecommunication charges or insurance attributable to the delivery of the articles or things or computer software outside India or expenses, if any, incurred in foreign exchange in providing the techni ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0. 2. The facts in brief are that the Assessee was engaged in the business of Business Process Outsourcing ('BPO') which provides back office services to its overseas clients. The unit of the Assessee was eligible for deduction under Section 10A of the Act. During the course of the assessment proceedings, the Assessing Officer ('AO') noticed that the Assessee had incurred certai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... om export turnover for computing deduction under Section 10A of the Act. The CIT (A) further held that there was no nexus between the communication expenses and the export of services. 4. Aggrieved by the order of the CIT (A), the Revenue preferred an appeal before the ITAT. In its impugned order the ITAT noticed that since the Assessee had not incurred expenses in foreign exchange for providin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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