CIT v. Ajay Agarwal (HUF) (2018) 99 taxmann.com 18 / 259 Taxman 134 (Bom.) (HC) Editorial : SLP of revenue is dismissed ,CIT v. Ajay Agarwal (HUF) (2018) 259 Taxman 133 (SC)

S. 10A : Free trade zone – Development of software- Receiving basic engine from non-eligible unit, developed software at its eligible unit -Entitle to exemption. [S. 260A]

Dismissing the appeal of the revenue  High Court held that, receiving basic engine from non-eligible unit, developed software at its eligible unit the assessee is entitle to exemption. Finding of the AO that software was substantially developed at non-eligible unit and thereafter it was placed in hard disk and shifted to eligible unit only with an intent to claim exemption was rightly rejected by the Tribunal. (AY. 2009-10)