Export profit allocation: proportional rule introduced and on site foreign software development deemed export for tax exemption. Amendments recast commencement language for manufacturing or software activity, replace the profit attribution rule with a proportional allocation based on export turnover relative to total turnover, exclude specified shareholding changes (public interest or venture capital disinvestment) from disqualification, narrow an explanation to exports by the undertaking, and deem on site software development outside India to be export income for purposes of the exemption.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Export profit allocation: proportional rule introduced and on site foreign software development deemed export for tax exemption.
Amendments recast commencement language for manufacturing or software activity, replace the profit attribution rule with a proportional allocation based on export turnover relative to total turnover, exclude specified shareholding changes (public interest or venture capital disinvestment) from disqualification, narrow an explanation to exports by the undertaking, and deem on site software development outside India to be export income for purposes of the exemption.
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