https://www.taxtmi.com/caselaws?id=218833 The High Court upheld the Commissioner's directive to reassess the deduction under Section 80HHE instead of Section 80-O for income from software development and technical services outside India. Specific provisions like Section 80HHE were deemed to prevail over general provisions like Section 80-O in such cases. The Court emphasized the need for a detailed examination of contracts and materials to determine the appropriate deduction section. The Revenue's appeals were allowed, setting aside the Tribunal's decision in favor of the Commissioner's order under Section 263. en-us Thu, 14 Jun 2012 00:00:00 +0530 Thu, 31 Oct 2013 11:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218833 The High Court upheld the Commissioner's directive to reassess the deduction under Section 80HHE instead of Section 80-O for income from software development and technical services outside India. Specific provisions like Section 80HHE were deemed to prevail over general provisions like Section 80-O in such cases. The Court emphasized the need for a detailed examination of contracts and materials to determine the appropriate deduction section. The Revenue's appeals were allowed, setting aside the Tribunal's decision in favor of the Commissioner's order under Section 263. Case-Laws Income Tax Thu, 14 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218833