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    <title>2025 (5) TMI 1417 - MADRAS HIGH COURT</title>
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    <description>The HC ruled on multiple substantial questions of law regarding deductions under Sections 10A, 80HHE, and 80M of the Income Tax Act. The court held that expenses incurred in foreign exchange for providing technical services cannot form part of &quot;export turnover&quot; - only amounts received in foreign exchange qualify. The court distinguished between manufacturing computer software and providing technical services, ruling in favor of the assessee on this distinction. However, the court ruled against the assessee on computation of deductions, stating no scope exists for mixing income and expenses under Sections 10A and 80HHE. The matter was partially remitted back to the Assessing Officer for proper computation after determining whether the assessee actually exported computer software or provided technical services outside India.</description>
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      <link>https://www.taxtmi.com/caselaws?id=771145</link>
      <description>The HC ruled on multiple substantial questions of law regarding deductions under Sections 10A, 80HHE, and 80M of the Income Tax Act. The court held that expenses incurred in foreign exchange for providing technical services cannot form part of &quot;export turnover&quot; - only amounts received in foreign exchange qualify. The court distinguished between manufacturing computer software and providing technical services, ruling in favor of the assessee on this distinction. However, the court ruled against the assessee on computation of deductions, stating no scope exists for mixing income and expenses under Sections 10A and 80HHE. The matter was partially remitted back to the Assessing Officer for proper computation after determining whether the assessee actually exported computer software or provided technical services outside India.</description>
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