Dismissing the appeal of the revenue the Court held that, undertaking starting manufacture on or after 1-4-1995 must have 75 Per Cent. of sales attributed to export. Apportionment of expenses is held to be reasonable. Sub-contractors giving software support to assessee on basis of foreign inward remittance . Claim by sub-contractors would not affect assessee’s claim. (AY.2000-01)
CIT (LTU) v. IBM Global Services India Pvt. Ltd. (2020) 429 ITR 386 / ( 2021) 278 Taxman 72 (Karn.)(HC)
S. 10A : Free trade zone-Separate accounts need not be maintained- Undertaking starting manufacture on or after 1-4-1995 must have 75 Per Cent. of sales attributed to export-Apportionment of expenses is held to be reasonable-Sub-contractors giving software support to assessee on basis of foreign inward remittance-Claim by sub-contractors would not affect assessee’s claim. [S. 80HHE]