Is Deduction u/s 80HHE Available to Non Residents ?

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The assessee was a an Individual having tax residency of USA.The assessee had a Permanent Establishment in India (‘PE’) in form of proprietary concern for export of software.He claimed deduction u/s 80HHE in respect of export of softwares. However, both the Assessing Officer as well as the Commissioner (Appeals) were of the opinion that deduction…