Mere absence of any specific provision treating inter-branch transfer as export, would not deny deduction u/s 10A to the assessee on transfer of software to HO outside India. Further, this logic was also strengthened by provision of section 80-IA(8) which was part of section 10A. (AY. 2008-09)
Dy. CIT v. Virage Logic International (2018) 63 ITR 10 (SN)(Delhi)(Trib.)
S. 10A : Free trade zone – Sale by the assessee to HO outside India would amount to Export eligible for deduction u/s 10A of the Act.