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Issues: Whether foreign currency expenditure was required to be excluded from both export turnover and total turnover while computing deduction under section 10A.
Analysis: The dispute concerned computation of deduction under section 10A in relation to expenses incurred in foreign currency. The applicable legal position had already been settled by the Supreme Court, and the departmental circular also directed that appeals should not be pursued on the issue. In view of the settled law, the exclusion had to operate consistently for both export turnover and total turnover.
Conclusion: The issue was decided against the Revenue and in favour of the assessee.