The assessee included a sum of Rs.1,23,66,641/-as export receipt, which was stated to be a ‘deemed export ‘ towards software development to another Software Technology Park (STP) Unit. The contention of the assessee was that if software was supplied to an STP Unit, it should be a ‘deemed support‘ as per the Foreign Trade Policy vis-a-vis the Income Tax Act, 1961. The Assessing Officer held that as per the contract agreement between the assessee and the principal, the work had to be carried out in India. Further, he found that the receipt for such work was received in Indian rupees only, as the payment was routed through the Hyderabad office of the principal. Accordingly, the export turnover of the assessee was recomputed and reduced to Rs.6,84,25,755/-and the Assessing Officer disallowed the deduction under Section 10A of the Act amounting to Rs.1,23,57,188/-after holding that the supply would not fall within the scope of the word ‘export‘ as defined under the provisions of the Income Tax Act. The order of Assessing Officer was affirmed by the CIT (A) and Appellate Tribunal .   Referred   Tata Elxsi Ltd. v . ACIT  (2015) 94 CCH 0202] (Karn) (HC)    PCIT, Bangalore . International Stones India (P) Ltd.  in (2018) 95 Taxmann.com 287 (Karn )(HC)    Tulsyan Nec Ltd. v . Assistant Commissioner (CT)(2015) 82 VST 63 (AY.  2009-10)