https://www.taxtmi.com/caselaws?id=120836 For section 10A computation, 80 per cent of uplinking charges was treated as attributable to software delivery outside India and was excluded from export turnover; the same charges were also required to be excluded from total turnover to maintain a consistent formula. The loss-set-off issue for one STP unit was not finally resolved because the record did not clearly show whether that unit was a separate undertaking or part of an integrated composite unit, so the matter required factual verification. Deduction under section 10A was allowed on income computed at arm's length price where the Assessing Officer had not enhanced income under section 92C(4). en-us Tue, 27 Nov 2007 00:00:00 +0530 Tue, 09 Jan 2024 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=120836 For section 10A computation, 80 per cent of uplinking charges was treated as attributable to software delivery outside India and was excluded from export turnover; the same charges were also required to be excluded from total turnover to maintain a consistent formula. The loss-set-off issue for one STP unit was not finally resolved because the record did not clearly show whether that unit was a separate undertaking or part of an integrated composite unit, so the matter required factual verification. Deduction under section 10A was allowed on income computed at arm's length price where the Assessing Officer had not enhanced income under section 92C(4). Case-Laws Income Tax Tue, 27 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=120836