https://www.taxtmi.com/caselaws?id=180685 Section 80HHE deduction was computed by following the assessee's earlier-year method on reduction of foreign currency expenditure from export and total turnover, and the relief was allowed. Article 23 DTAA relief was confined to income actually taxed in India, so the Canadian tax credit could not be claimed on the entire royalty receipt; the computation method was upheld with figure revision. DTAA credit was not to be deducted before calculating surcharge. Profit on sale of Eagle Software was treated as business income from the eligible STP unit, not capital gains, and qualified for exemption under section 10A. en-us Tue, 05 Jul 2005 00:00:00 +0530 Thu, 25 Apr 2024 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180685 Section 80HHE deduction was computed by following the assessee's earlier-year method on reduction of foreign currency expenditure from export and total turnover, and the relief was allowed. Article 23 DTAA relief was confined to income actually taxed in India, so the Canadian tax credit could not be claimed on the entire royalty receipt; the computation method was upheld with figure revision. DTAA credit was not to be deducted before calculating surcharge. Profit on sale of Eagle Software was treated as business income from the eligible STP unit, not capital gains, and qualified for exemption under section 10A. Case-Laws Income Tax Tue, 05 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180685