2019 (1) TMI 1862

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....anding Counsel. For the Respondent : Mr. R. Sivaraman JUDGMENT [Judgment of the Court was delivered by Dr. Anita Sumanth, J.] Revenue has filed these appeals under Section 260A of the Income Tax Act, aggrieved by common order dated 06.03.2009, passed by the Income Tax Appellate Tribunal (in short, 'Tribunal'), in respect of Assessment Years 2002-2003 and 2003-2004 respectively.....

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.... of the Supreme Court in the case of Commissioner of Income Tax v. HCL Technologies Ltd., (2018) 404 ITR 719 (SC). The operative portion of the judgment is as follows : "19. In the instant case, if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under Section 10A of the IT Act are allowed only in Export Turnover but not from the Total....