In Brief
In this consolidated appeal, the Supreme Court addressed whether expenses for software development and technical services provided outside India should be excluded from 'total turnover' when computing deductions under Section 10A of the Income Tax Act. The Court held that the definition of 'total turnover' from Sections 80HHC and 80HHE cannot be applied to Section 10A since such definitions are stated to apply only to those specific sections. Applying the rule of harmonious construction, the Court found that freight, telecommunication, insurance, and foreign exchange expenses for technical services outside India must be excluded from total turnover in the same proportion as excluded from export turnover, to produce a meaningful and consistent formula and give effect to legislative intent. All appeals were dismissed.
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