Tax holiday not available to a foreign branch carrying on-site software development and full-fledged marketing operation

Tax holiday not available to a foreign branch carrying on-site software development and full-fledged marketing operations – Delhi HC Facts •           Interra Software India Private Limited (ISIPL) had a software development unit in NOIDA Export Processing Zone (NEPZ). It was a 100% export oriented unit engaged in the business of development of software and therefore eligible for deduction under section 10A of the Indian Income tax Act ( “the Act”) . •           ISIPL had, with the approval of RBI, opened a non-trading branch in Tokyo, Japan to facilitate communic...