Court held that t unrealised sale proceeds could not be included in the total turnover and excluded from the export turnover. Followed CIT v. HCL Technologies Ltd ( 2018) 404 ITR 719 (SC) . Court also held that  on a perusal of the contract, it was clear that the element of “technical services”, had been rendered as an integral part of the software development process. There was no material available before the Assessing Officer to split the transaction into two or to bisect the transaction to find out an element of “technical services”. The technical services rendered by the assessee were not on a “standalone basis”, but as an integral part of the software development, the assessee was bound to render all assistance to the foreign entity. Therefore, the artificial splitting of the transaction by the Assessing Officer, that too without any materials on his file, was wholly unsustainable. The expenditure incurred in foreign currency in export of software was includible in export turnover for purposes of section 10A .  ( AY. 2001 -02 , 2002 -03 )