Dismissing the appeal of the revenue the Court held that under Finance Act of 2000, the provisions of section 10A came to be amended giving benefit of deduction in relation to the income from the manufacturing activities of computer software development for export- This amendment would take effect from 1/4/2001. In the return of income filed for the assessment year 2005-06, the assessee had claimed such deduction in terms of section 10A of the Act, instead of section 80HHE.  Court also held that  expenses which are to be excluded from the export turnover would also have to be excluded for the purpose of computing total turnover.  ( AY. 2005 -06)