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TMI Blog2021 (11) TMI 216X X X X Extracts X X X X X X X X Extracts X X X X ..... n applies to the total turnover as well. DR fails to dispute that not only the hon'ble apex court's landmark decision in CIT Vs. HCL Technologies Ltd. [ 2018 (5) TMI 357 - SUPREME COURT] has settled the instant issue but also the CBDT has issued its circular No. 4/2018, dt. 14-08-2018 that such an item; excluded from the export turnover, is not included in the total turnover as well. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion u/s. 10A of the Act. b. The Ld. CIT(A) erred in rejecting Additional Ground nos. 11 12 taken before him. c. The Ld. CIT(A) erred in reducing from export turn over, on site development proceeds of US Branch for ₹ 42,86,17,492/- in his computation of deduction u/s. 10A of the Act. d. The Ld. CIT(A) ought to have appreciated that the on site I development proceeds of US B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /s. 10A of the Act. g. The Ld. CIT(A) grossly erred in observing that the appellant had failed in bringing any evidence regarding the contracts and repatriation of amounts to India. h. The Ld. CIT(A) ought to have appreciated that any delay in actual repatriation of the impugned sale proceeds to India is immaterial when once the impugned sale proceeds are credited in a separate bank acco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of hearing of the appeal . 3. We have heard rival submissions against and in support of the impugned export turnover disallowance of ₹ 42,86,17,492/-. We find force in the assessee's ground No. (i) to be specific wherein its case is that whatever revenue item is excluded from export turnover, the very course of action applies to the total turnover as well. Learned departmental r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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