https://www.taxtmi.com/caselaws?id=334438 Section 10A can apply to an inter-branch transfer of computer software from an Indian branch to an overseas head office when the statutory conditions are met and consideration is received in convertible foreign exchange. Read with Section 80-IA(8) through Section 10A(7), the provision allows transfer pricing-style valuation of inter-unit supplies and does not require a sale to an outside customer. The absence of an express deemed-export clause does not defeat the statutory fiction. Accordingly, software developed by the branch for the head office's requirements may still qualify for Section 10A deduction. en-us Wed, 09 Nov 2016 00:00:00 +0530 Tue, 31 Jan 2017 18:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334438 Section 10A can apply to an inter-branch transfer of computer software from an Indian branch to an overseas head office when the statutory conditions are met and consideration is received in convertible foreign exchange. Read with Section 80-IA(8) through Section 10A(7), the provision allows transfer pricing-style valuation of inter-unit supplies and does not require a sale to an outside customer. The absence of an express deemed-export clause does not defeat the statutory fiction. Accordingly, software developed by the branch for the head office's requirements may still qualify for Section 10A deduction. Case-Laws Income Tax Wed, 09 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334438