https://www.taxtmi.com/caselaws?id=234989 Training fee receipts earned by a 100% export-oriented undertaking were held not to fall within the exemption under Section 10B because the provision covers only profits and gains derived from manufacture or production of an article or thing. Fees charged for training outsiders or non-employees were treated as commercial receipts, not income derived from software production or other qualifying output. The Software Technology Park scheme and customs circulars could not expand the statutory scope of the Income-tax Act. Applying strict construction to the exemption, relief was denied for the relevant year, and the later-year Revenue appeals were allowed. en-us Wed, 05 Jun 2013 00:00:00 +0530 Mon, 28 Oct 2013 09:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234989 Training fee receipts earned by a 100% export-oriented undertaking were held not to fall within the exemption under Section 10B because the provision covers only profits and gains derived from manufacture or production of an article or thing. Fees charged for training outsiders or non-employees were treated as commercial receipts, not income derived from software production or other qualifying output. The Software Technology Park scheme and customs circulars could not expand the statutory scope of the Income-tax Act. Applying strict construction to the exemption, relief was denied for the relevant year, and the later-year Revenue appeals were allowed. Case-Laws Income Tax Wed, 05 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234989