Assessee, engaged in export of software solutions and maintenance services, was denied exemption under section 10A on the ground that export turnover brought into India was less than 75% of the total turnover of the software technology park unit, since AO considered only net inward remittances after deducting onsite expenses and sub-contractor payments, though CIT(A) held that payments to sub-contractors outside India did not affect the exemption claim and allowed the exemption. On appeal, the Tribunal held that in the absence of a definition of “export turnover” in section 10A for the relevant year, AO had erroneously borrowed the definition of “export turnover” from section 80HHE while ignoring the corresponding definition of “total turnover” therein, whereas expenditure incurred in foreign exchange in providing technical services outside India, being excluded from “total turnover”, must equally be excluded from “export turnover” so that both bear a consistent meaning; since section 10A is a beneficial provision intended to promote exports and confer a larger benefit than section 80HHE, AO was directed to compute the 75% of total sales on gross receipts under section 10A(2)(ia). (AY.2000-01)