Interpretation of the words "manufacture or production" for the purpose of deduction U/s. 10B

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3.5 We have heard rival contentions on this aspect. The taxpayer company was incorporated on 10.6.1988 . The taxpayer is stated-to be engaged in the business of software development since 1994 and its unit has been granted the status of 100% export oriented software technology park on 31.8.1995 under the software export scheme of Department of Electronics and thus, has been granted the status of 100% EOU. As per annexure-A to

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