Dismissing the appeal of the revenue the Court held that for eligible for exemption export should earn foreign exchange, it does not mean that undertaking should personally export goods manufactured /software developed by it outside Country. It might export out of India by itself or export out of India through another STP Unit. If deductions on freight telecommunication and insurance attributable to delivery of computer software were allowed only in Export turn over but not from total turn over then it would give rise to inadvertent un lawful and illogical result which would cause grave in justice to assessee which could never been intention of the legislature. Followed  Tata Eixsi Ltd v. ACIT ( 2015) 127 DTR 327 ( Kran.)(HC)  (AY. 2009 -10)