Assessee was a design engineering company. It filed its return of income claiming exemption under section 10A in respect of its new unit. Assessing Officer held that changes were made to existing unit and no new unit was set-up by assessee  and the assessee had not purchased the land.  Tribunal held the assessee was engaged in on site development of software program. Programs were delivered at premises of client at work site in foreign country. Activities of assessee finally culminated at work site of clients outside India and there was no need for full fledged infrastructure facilities in India. Accordingly   new industrial undertaking of assessee was independent of all undertakings which it was already possessing and allowed the exemption. On appeal by the revenue High Court  affirmed the view of the Appellate Tribunal   (AY.  2007-08)