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2014 (1) TMI 1815 - AT - Income TaxTPA - rejection/selection of comparables by TPO - selection criteria - Held that:- Assessee is engaged in software development services. Assessee can be termed as a captive service provider, thus companies functionally dissimilar with that of assessee need to be deselected from final list of comparability. Reduce the communication expenses attributable to delivery of software outside India both from the export turnover and total turnover for the purpose of computing deduction u/s 10A of the Act. See CIT vs. Gem Plus Jewellery India Ltd. (2010 (6) TMI 65 - BOMBAY HIGH COURT )
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