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2017 (2) TMI 1211 - AT - Income TaxTPA - Comparability Analysis adopted by the TPO for determination of arm's length price - Held that:- Assessee is engaged in the business of providing software development services for which it is remunerated on a cost plus 15% margin, thus companies functionally dissimilar with that of assessee need to be excluded from final list of comparable. Deduction u/s. 10A - Held that:- As fairly contended that this issue is squarely covered by the case of CIT v. Tata Elxsi Ltd.(2011 (8) TMI 782 - KARNATAKA HIGH COURT) in which it has been held that once a particular item is to be excluded from the export turnover, it should also be excluded from the total turnover. We accordingly following the same, set aside the order of the CIT(Appeals) and restore the matter to the file of Assessing Officer with a direction to recompute the deduction u/s. 10A following the judgment supra.
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