2016 (2) TMI 1123 - ITAT BANGALORE

Computation of the deduction under Section 10-A - Exclusion of expenditure incurred in foreign exchange from export turnover as well as from total turnover - Held that:- As held by the Hon’ble High Court in Tata Elxsi Ltd (2011 (8) TMI 782 - KARNATAKA HIGH COURT) expenses excluded from export turnover had to be excluded from the total turnover also while working out the eligible deduction.

Exclusion of certain comparables by the DRP for the purpose of determining the arm’s length price [ALP] - TPA - Held that:- The assessee is a company and engaged in the business of developing software solution services as well as rendering sales and support services for its products. The assessee provides two category of services; software development and sales & marketing support services. The assessee has entered into separate agreements for provision of software development as well as sales & marketing services to its group EFI. Companies functinally dissimilar with that of assessee need to be deselected from final list of comparables.