Tribunal held that expenditure incurred towards data link charges, Telecommunication charges and foreign travel expenses attributable to delivery of computer software for providing technical services outside India is excludible both from export turnover and total turnover . Profits enhanced owing to disallowance of payments for failure to deduct tax at source. Enhanced profits to be considered for deduction. Export proceeds received in India beyond time-limit but within time allowed by Reserve Bank circular to be considered for deduction . Followed , CIT v. HCL Technologies Ltd.( 2018) 404 ITR 719 (SC) CIT v. Gem plus Jewellery India Ltd ( 2011 ) 330 ITR 175 ( Bom) (HC) , ITO v. PCL Exports (IT A. No. 3563/Delhi/2009 dt. 22 -3 2011) ( AY.2009-10)