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2011 (2) TMI 709 - HC - Income TaxDeduction u/s 10B - Cochin Export Processing Zone - Directions u/s 144C - the Dispute Resolution Panel has taken into consideration the aspect of exemption under section 10A of the Act as not available in so far as Rs. 305 crores which was arrived at by the Assessing Officer in the draft assessment and also issued a direction referring to clause (5) of section 144C of the Act. - held that:- It appears it is not as if the matter has been concluded by the Dispute Resolution Panel. Rather it has kept open the issue whether engineering and design services fall within the definition of "computer software" or not for the purpose of extending the benefit of exemption, to be decided by the Assessing Officer, after hearing the petitioner. - the direction issued by the Dispute Resolution Panel is not in violation of section 144C(5) or (8) of the Act. - Decided against the assessee.
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