INCOME TAX : Where assessee claimed exemption under section 10A in respect of its new unit, since assessee was engaged in site development of software program and programs were delivered at premise of client at work site in foreign country and activities of assessee finally culminated at work site of clients outside India and there was no need for full fledged infrastructure facility in India, thus, industrial undertaking of assessee was independent of all undertakings which it already possessed
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