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2015 (5) TMI 1108 - AT - Income TaxTPA - Adjustment to ALP to an international transaction carried out by the assessee u/s. 92CA - selection of comparable - Held that:- Assessee is a company as rendered software development Services to its Associated Enterprise(AE) thus companies with functional dissimilarity 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 and traveling expenses incurred in foreign currency both from export turnover and total turnover, as has been prayed for in the alternative by the assessee
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