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2015 (10) TMI 2716 - AT - Income TaxTransfer pricing addition - comparable selection criteria - functional similarity - Held that:- The assessee is into software design and development services thus companies functionally dissimilar with that of assessee need to be deselected from final list. Deduction u/s 10A - data link charges being excluded from the export turnover - Held that:- By virtue of definition of export turnover given Explanation-2(iv) to Sec.10A of the IT Act, 1961, interpretation sought by the assessee cannot be accepted. However, its alternative contention for exclusion of such amount from the total turnover also, while calculating deduction u/s 10A of the IT Act, 1961 is reasonable in view of case of CIT Vs M/s Tata Elxsi Ltd., (2011 (8) TMI 782 - KARNATAKA HIGH COURT)
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