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of <h1>Clarification on Section 80HHE: On-site Software Development Profits Abroad Qualify for Export Deductions, Retroactive from 1991.</h1> The circular clarifies the applicability of the Explanation under Section 80HHE(1) of the Income-tax Act, 1961, concerning deductions for profits from the export of computer software. It states that profits from on-site development of software outside India are considered as export profits. Although the Explanation was added by the Finance Act, 2001, effective from April 1, 2001, it is deemed clarificatory. Therefore, it is retroactively applicable from April 1, 1991, the date when Section 80HHE originally came into effect. This clarification ensures consistency in interpreting the law regarding software export profits.
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