Dismissing the appeal of the revenue the Court held that the Tribunal was right in holding that the internet expenses incurred in foreign exchange having been excluded from the export turnover should be reduced from the total turnover for the purpose of computing deduction under section 10A. That the Tribunal was right in holding that the assessee was entitled to deduction under section 10A in respect of the new unit. That the Tribunal was right in holding that the assessee’s claim for deduction under section 10A was to be allowed before adjusting the brought forward losses and unabsorbed depreciation. (AY. 2005-06)
CIT v. SRA Systems Ltd. (2021) 434 ITR 656 (Mad.)(HC)
S. 10A : Free trade zone-Interest charges attributable to delivery of computer software-Excluded from export turnover-Deducted from total turnover-New unit-Entitle to deduction-Brought forward losses and unabsorbed depreciation-Deduction to be allowed before adjusting brought forward losses and unabsorbed depreciation. [S. 10A(2)(i), 10A(2)(ii)]