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2017 (4) TMI 1375 - ITAT BANGALORETransfer pricing addition - comparable selection criteria - functional similarity - Held that:- The assessee has set up offshore development centre for catering to the software development and maintenance need of the group in the global trade and logistic domain. Therefore the assessee is providing software development services to its AE, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Exclusion of the expenditure incurred in foreign currency from export turnover as well as total turnover while computing the deduction under Section 10A - Held that:- Respectfully following the aforementioned decision of the Hon’ble High Court of Karnataka in the case of Tata Elxsi Ltd. [2015 (10) TMI 634 - KARNATAKA HIGH COURT], we uphold the finding of DRP in directing the Assessing Officer to reduce the expenditure incurred in foreign currency from both export turnover and total turnover for the purpose of computing the deduction under section 10A of the Act in the case on hand. Consequently this ground raised by revenue is dismissed.
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