TTEC India Customer Solutions P. Ltd. v ITO (2020)82 ITR 26 (SN)(Ahd) (Trib)

S. 10A : Free trade zone – Profits of the business- Export revenue subsidy — Miscellaneous income —Entitled for exemption [ S.10A(4) , 10B ]

Tribunal held that in view of the  statutory formula available for determination of  quantum of  deduction, the expression “Derived From” used In Section 10A(1) fades into insignificance and the quantum of  deduction is  required to be  determined as per the formula provided in section 10A(4) of the Act.  . The assessee was entitled to exemption in  respect of  the incidental profits along with the export Profits for the purposes of  section 10A . The Assessing Officer was directed to  compute the quantum of deduction,  as per the formula provided in  S. 10A(4)  of the Act . ( AY.2005-06)