Deduction U/s. 80HHF available on sale not on Production or mere allotment

RELEVANT PARAGRAPH 8. We have considered the facts of the case and rival submissions. Section 80HHF regarding deduction in respect of profits and gains from export or transfer of film software etc. This provision grants the deduction in a case, where the assessee is engaged in the business of export or transfer by any means out of India, of any film software, television software etc., including telecast rights. On closer examination, it becomes clear that either the film software should be exported outside India or transferred out of India by any means by the person resident in India. The ter...