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2015 (6) TMI 1122 - AT - Income TaxAdjustment in the arm’s length price(ALP) of international transaction - Held that:- The Assessee is a wholly owned subsidiary of Beceem Communications Inc. USA. The Assessee rendered software development services to its holding company thus companies functionally dissimilar with that of assessee need to be deselected from final list of comparable. Deduction u/s.10A computation - Held that:- Taking into consideration the decision rendered by the Hon’ble High Court of Karnataka in the case of CIT v. Tata Elxsi Ltd [2011 (8) TMI 782 - KARNATAKA HIGH COURT] we are of the view that it would be just and appropriate to direct the Assessing Officer to exclude telecommunication charges, internet charges etc., both from export turnover and total turnover, as has been prayed for by the assessee Disallowing expenditure for acquiring the rights to use application software - Held that:- It is not disputed by the revenue that the expenditure was in respect of application software. Thus we hold that expenditure incurred on purchase of software should be allowed as revenue expenditure.
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