Customization of electronic data amounts to manufacture for claiming exemption u/s 10B

Brief Facts of the case:Assessee is engaged in the activity of collection ,collation ,formatting of data and information and its export.In her return she had claimed exemption under section 10B of IT Act to the tune of Rs 39,32,654/-and she claimed to be software exporter to Netherlands. AO in its assessment disallowed the above claim and finalized the assessment . Sec “10B. (1) Subject to the provisions of this section, a deduction of such profits and gains as are derived by a hundred per cent export-oriented undertaking from the export of articles or things or computer software for a ...