https://www.taxtmi.com/caselaws?id=65569 Section 80HHE(5) bars a second deduction only for the same profits already allowed under that provision, and does not create a lifetime disqualification against claiming Section 10A exemption in later years where the statutory conditions are met. Export sales were treated as eligible for Section 10A relief because RBI extension for realisation existed and the proceeds were received within the extended period. Profits of the Japan branch from onsite software development services were also treated as exempt under Section 10A, as Explanation 3 deems such offshore development profits to be derived from export of computer software outside India. On that basis, the additions and disallowances were deleted. en-us Fri, 07 Sep 2007 00:00:00 +0530 Fri, 12 Jan 2024 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65569 Section 80HHE(5) bars a second deduction only for the same profits already allowed under that provision, and does not create a lifetime disqualification against claiming Section 10A exemption in later years where the statutory conditions are met. Export sales were treated as eligible for Section 10A relief because RBI extension for realisation existed and the proceeds were received within the extended period. Profits of the Japan branch from onsite software development services were also treated as exempt under Section 10A, as Explanation 3 deems such offshore development profits to be derived from export of computer software outside India. On that basis, the additions and disallowances were deleted. Case-Laws Income Tax Fri, 07 Sep 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65569