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2016 (1) TMI 1359 - AT - Income TaxTPA - comparable selection criteria - Held that:- Assessee is engaged in providing software development services of its holding company, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Computing deduction u/s.10A - excluding leaseline expenses from the export turnover on the ground that these expenses are attributable to delivery of software outside India from the export turnover - 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 insurance charges incurred be excluded both from export turnover and total turnover, as has been prayed for by the assessee in the alternative.
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