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2015 (12) TMI 1675 - AT - Income TaxExclusion of internet expenses from the export turnover treating it as incurred for delivery of software outside India for the purpose of computation of deduction under section 10A - Held that:- Following the case of CIT v M/s Tata Elxsi Ltd. & Others [2011 (8) TMI 782 - KARNATAKA HIGH COURT] we are inclined to accept the alternative contention of the assessee that if this expenditure is excluded from the export turnover, then the same should also be excluded from the total turnover for the purposes of computation of deduction under section 10A of the I.T. Act. T.P. adjustment - Held that:- Assessee is a 100% captive service provider and is engaged in the business of providing software development services to it’s A.E., thus companies functionally dissimilar with tat of assessee need to be de-selected from final list of comparable.
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