Assessee being a 100% Export Oriented Unit (EOU) for AYs in respect of deemed export of goods made by it during period under consideration through a third party. The Tribunal held that assessee was entitled to deduction under section 10B in respect of its profits and gains from its business. The High Court  relied on the order of its coordinate bench in the case of  CIT v Tata Elxsi   Ltd (2016) 127 DTR 327)(Karn.)(HC) and agreed with the view taken by the earlier division bench and dismissed the appeal of the revenue.  The High Court  held that the word ‘export’ read with background of Exim Policy of Union of India would certainly include ‘Deemed Export’ also within ambit of ‘Export Turnover’ as explained in Explanation 2 of section 10B(9A). Further, there was no restriction imposed under section 10B(2) on quantum of deduction eligible under section 10B(1) with reference to export of goods manufactured by unit itself.  Therefore, benefit of deduction under section 10B(1) cannot be restricted merely because the third party through which export has been made in not a 100% EOU. (AY. 2009-10, AY. 2010-11, 2011-12)