In Brief
HCL Technologies claimed deductions under Section 10A of the Income Tax Act for software exports, excluding certain expenses (freight, telecommunication, and technical services provided abroad) from its total turnover. The Revenue contended these should be included. The Supreme Court held that while Section 10A does not define 'total turnover,' the principle of harmonious statutory construction requires consistent treatment: any expense excluded from 'export turnover' must also be excluded from 'total turnover.' Otherwise, the formula calculating export profit would yield absurd results. The Court dismissed the Revenue's appeals and upheld the taxpayer's right to exclude such expenses from both the numerator and denominator of the deduction formula.
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