California Software Co. Ltd. v. CIT (2020)422 ITR 514 / 107 CCH 0458 / 275 Taxman 158 (Mad)(HC)

S. 10A : Free trade zone – Export oriented undertakings – Remission or cessation of trading liability – Profits derived from export- Reversal of the entry with regard to the stock option given to the employees was in the nature of export income- Entitled to exemption. [ S.10B , 41(1) ]

The assessee reversed   the entry with regard to the stock option given to the employees  and claimed exemption treating the said the income was in the nature of export income. The Tribunal decided against the assessee .On appeal the Court held that the income brought to tax under S.  41 by  reversal of the entry with regard to the stock option given to the employees was in the nature of export income and therefore, the assessee was entitled to exemption. Under S. 10A / 10B  of the Act .