Section 10B- Compiling, editing, digital designing of software amounts to Manufacture

Issue before court:

Whether assessee’s engagement in activities of collection, collation, formatting of data, editing, digital designing etc. can be termed at manufacturing to avail the benefits of section 10B of the Income-tax Act.

Brief facts:

♠ Assessee claimed to be software exporter to The Netherland engaged in the manufacturing of e-book software namely 100 Wonders of India and hence claimed exemption under section 10 amounting to Rs. 39,32,594/-.

♠ AO being unsatisfied denied exemption and disallowed the amount claimed by assessee u/s 10 B.

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