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2014 (11) TMI 1159 - AT - Income TaxTPA - comparable selection -Held that:- Assessee provides services in the fields of Software Technology Services, Outsourcing Services and Customized software development services to its AEs, thus companies functionally dissimilar with that of assessee need not to be selected to final comparability list. Reducing the loss of loss making unit from profit making units for the purposes of section 10A - Held that:- As relying on case of Unilever Ltd. vs DCIT [2010 (4) TMI 206 - BOMBAY HIGH COURT] wherein held the loss of one unit under section 10A of the Act shall be adjusted against the income liable for deduction under the same but in relation to the income from other unit, we direct the AO to recompute the exemption under section 10A Exclusion of telephone expenses from the computation of exemption under section 10A - Held that:- We set aside the orders of the revenue authorities and direct the AO to delete the disallowance and compute the exemption as per law and keeping in view the decision of the Hon’ble Bombay High Court in the case of the assessee. Treatment of grant received by the assessee from government - revenue or capital expenditure - Held that:- Respectfully following the decision of Hon’ble Supreme Court in Ponni Sugars (2008 (9) TMI 14 - SUPREME COURT ) we reverse the orders of the revenue authorities and direct the AO to treat the grant as capital in nature and delete the disallowance.
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