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2011 (11) TMI 455 - KARNATAKA HIGH COURTDeduction u/s 10A - consideration received for sale of eagle software by assessee to foreign subsidiary against allotment of shares as trading receipt against as held by assessee as long term capital gain - alternative claim of deduction u/s 10A and 80HHE denied by Revenue - Held That:- Material on record reveals that assessee was STP unit when sale transaction took place. Also, expenditure incurred towards manufacture of the said software has been included in profit and loss account for the respective assessment years. Therefore, income received by the sale of Eagle software is to be treated as trade receipt and assessee is entitled to exemption admissible u/s 10A - Decided in favor of assessee. Amount paid to various clubs - Held that:- Same is to be allowed as revenue expenditure as reling on assessee's own case [2013 (2) TMI 629 - Karnataka High Court] - In favor of assessee. Deduction of expenditure incurred in foreign exchange for the purpose of deduction u/s 80HHE - Held that:- Tribunal was not correct in holding that deduction u/s 80HHE should be allowed to the assessee without excluding the foreign exchange expenditure incurred by the Assessee as relying on its own case [2013 (6) TMI 193 - KARNATAKA HIGH COURT] - Decided against the assessee.
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