2018 (2) TMI 443

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..... s within the description of an activity that qualifies for deduction under Section 10A. The lower authorities, we also note this, have relied upon certain other decisions, which take the extended or enlarged meaning of the expression “service” so as to imply not mere manufacture or production of articles or goods but other services. This view is reflected by the Court’s judgment in Commissioner of .....

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..... Officer had denied the deduction claimed by the assessee/respondent under Section 10A of the Income Tax Act, 1961 (hereafter referred to as the Act ). The material part of the AO s finding was that the assessee had not provided any material to establish that it was engaged in software manufacture and export and what it disclosed were transactions with the parent company and not with other indepe .....

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..... a or other information storage device or (b) Any customized electronic data or any product or service of similar nature. 4. It is quite apparent that customized electronic data or product or service clearly falls within the description of an activity that qualifies for deduction under Section 10A. The lower authorities, we also note this, have relied upon certain other decisions, which t .....

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