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2017 (1) TMI 1489 - AT - Income TaxTPA - comparable selection criteria - Held that:- Assessee is engaged in the business of computer software development services, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Computation of deduction u/s 10A - Held that:- Action of the DRP in directing the AO to exclude data link charges and freight charges both from turnover as well as total turnover while computing deduction u/s 10A, we do not find any infirmity in the order of the DRP as it is in conformity with the ratio laid down by the Hon’ble Bombay High Court in case of CIT vs. Gem Plus Jewellery (2010 (6) TMI 65 - BOMBAY HIGH COURT) as held that communication charges attributable directly to the export of article or thing outside India has to be excluded both from export turnover as well as total turnover while computing exemption u/s 10A of the Act
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