Export profits from on site software development deemed export income, with clarificatory retrospective application of the provision. The Explanation to section 80HHE treats profits and gains from on site development of computer software (including services for development) performed outside India as deemed profits from export of computer software outside India; although inserted with effect from 01 04 2001, the Board considers the Explanation clarificatory and to have effect from the date on which section 80HHE originally came into force, thereby applying the deeming rule from that earlier commencement date.