Computation of admissible deduction u/s 10A of the Income Tax Act, 1961 - Regarding

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..... xport turnover in respect of such articles or things or computer software bears to the total turnover of the business carried on by the undertaking. 2. Further as per clause (iv) to Explanation 2 to section 10 A of the Act , export turnover means the consideration in respect of export by the undertaking of articles or things or computer software received in, or brought into, India by the assessee in convertible foreign exchange in accordance with sub-section (3), but does not include 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 technical services outside India. 3. The iss .....

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..... Court, inter-alia, held that when a particular word is not defined by the legislature and an ordinary meaning is to be attributed to it, the said ordinary meaning is to be in conformity with the context in which it is used. Hence, what is excluded from export turnover must also be excluded from total turnover , since one of the components of total turnover is export turnover. Any other interpretation would run counter to the legislative intent and would be impermissible. 18) Accordingly, the formula for computation of the deduction under Section10A of the Act would be as follows: Export Profit = total Profit of the Business X Export turnover .....

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..... turnover. 5. The issue has been examined by the Board and it is clarified that freight, telecommunication charges and insurance expenses are to be excluded both from export turnover and total turnover , while working out deduction admissible under section 10A of the Act to the extent they are attributable to the delivery of articles or things or computer software outside India. 6. Similarly, expenses incurred in foreign exchange for providing the technical services outside India are to be excluded from both export turnover and total turnover while computing deduction admissible under section 10A of the Act . Thus, all charges/expenses specified in Explanation 2(iv) to section 10A of the Act, are liable to be .....

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