Sec 10A benefits cannot be denied on foreign exchange fluctuation gain linked to exports

Sanyo LSI Technology India Private Ltd Vs DCIT (ITAT Bangalore)– Gain from fluctuation of foreign exchange is directly related with the export activities and should be considered as income derived from export in the year in which the export took place for the purpose of deduction u/s 10A of the Act. The exchange value based on upward or downward of the rupee value is not in the hands of the assessee. The assessee does not determine the exchange value of the Indian rupee; that when the fluctuation in foreign exchange rate was solely relatable to the export business of the assessee and the higher rupee value was earned by virtue of such exports carried out by the assessee, there was no reason why the benefit of s. 10A should not be allowed to the assessee.