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2018 (3) TMI 1198 - ITAT DELHITPA - ALP determination - comparable adjustment - Held that:- Assessee is providing back office services relating to creation and maintenance of database of prospective employers and candidates who have sent their resumes to HSII in accordance with the preset criteria developed by HSII and including into search palace, thus companies functionally dissimilar with that of assessee need to be deselected from final-list. Exclusion of telecommunication expenses from the total turnover in order to calculate deduction u/s 10A - Held that:- When it is not in dispute that for the purpose of section 10A, the term “total turnover” is to be interpreted by computing the entire export turnover as well as domestic turnover and in case, expenses are to be excluded from export turnover, the same are to be excluded from the total turnover also for the purpose of computing the deduction u/s 10A of the Act. So, we are of the considered view that ld. CIT (A) has rightly directed the AO to exclude the telecommunication expenses amounting to ₹ 9,15,422/- from total turnover for the purpose of calculating the deduction u/s 10A of the Act.
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