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    <title>2020 (6) TMI 167 - ITAT DELHI</title>
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    <description>Section 10A computation is discussed in relation to export proceeds, export turnover, software trading income and tax deduction at source on commission payments. Belated realisation of export proceeds was not accepted on the facts, and foreign currency expenditure was upheld as excludible from export turnover for deduction purposes. Profits from trading of third-party software were sent back for fresh examination because the record did not establish a material factual foundation on export-oriented status. Export commission paid to non-residents was treated as outside the scope of income accruing or arising in India, so tax deduction at source was held inapplicable where taxable nexus was not shown.</description>
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      <link>https://www.taxtmi.com/caselaws?id=395792</link>
      <description>Section 10A computation is discussed in relation to export proceeds, export turnover, software trading income and tax deduction at source on commission payments. Belated realisation of export proceeds was not accepted on the facts, and foreign currency expenditure was upheld as excludible from export turnover for deduction purposes. Profits from trading of third-party software were sent back for fresh examination because the record did not establish a material factual foundation on export-oriented status. Export commission paid to non-residents was treated as outside the scope of income accruing or arising in India, so tax deduction at source was held inapplicable where taxable nexus was not shown.</description>
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