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2017 (1) TMI 1571 - ITAT HYDERABADTPA - selection of comparable companies - Held that:- Assessee provides software development services to its Associated Enterprise [AE], thus companies functionally dissimlar with that of assessee need to be deselected from final list. Deduction u/s 10A computation - Held that:- Hon’ble Bombay High Court in the case of CIT Vs. Gem Plus Jewellery India Ltd., [2010 (6) TMI 65 - BOMBAY HIGH COURT] (Bom) and ITO Vs. Sak Soft Ltd. [2009 (3) TMI 243 - ITAT MADRAS-D] wherein it has been held that communication charges etc., attributable to the delivery of the computer software outside India which are to be reduced from the export turnover should be reduced from the total turnover as well, while computing the deduction u/s. 10A. Therefore, we approve the direction of DRP to the AO to reduce the amount from the export turnover as well as from total turnover, while computing the deduction u/s. 10A of the I.T. Act.
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