Once data stored in electronic form, it becomes a customized electronic data which can be exported to qualify for deduction u/s 10A

RELEVANT PARAGRAPH 5. I have duly considered the rival contentions and the material on record. The issue to be considered is whether the profit earned by the assessee from the activity of recruitment and training of personnel and supplying the data thereof to its parent company in US is eligible for deduction under sec. 10A or not read with the Board’s Circular dated 26.09.2000. In this connection, it would be worthwhile to consider first the role of the circulars issued by the Board. ROLE OF BOARD’S CIRCULARS 6. This is best explained by the Supreme Court in the case of UCO Bank v...