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    <title>2014 (11) TMI 1202 - ITAT BANGALORE</title>
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    <description>Software expenditure claimed as revenue expenditure and the claim for deduction on salary paid to software engineers were both remitted for fresh examination because the issues depended on factual reappraisal, including the nature of the purchases and whether the employees qualified as workmen; both matters were thus allowed for statistical purposes. For deduction under section 10A, telecommunication charges and foreign currency technical services had to be excluded from both export turnover and total turnover, following the settled parity principle in the computation formula, and the Revenue&#039;s challenge failed. Penalty proceedings under section 271(1)(c) were held premature at the stage of mere notice, since no penalty order had yet been passed.</description>
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      <title>2014 (11) TMI 1202 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=281972</link>
      <description>Software expenditure claimed as revenue expenditure and the claim for deduction on salary paid to software engineers were both remitted for fresh examination because the issues depended on factual reappraisal, including the nature of the purchases and whether the employees qualified as workmen; both matters were thus allowed for statistical purposes. For deduction under section 10A, telecommunication charges and foreign currency technical services had to be excluded from both export turnover and total turnover, following the settled parity principle in the computation formula, and the Revenue&#039;s challenge failed. Penalty proceedings under section 271(1)(c) were held premature at the stage of mere notice, since no penalty order had yet been passed.</description>
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