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2013 (10) TMI 763 - AT - Income TaxInterpretation of Total Turnover & Export Turnover under 10A - Held That:- In the case of ITO v. Sak Soft Ltd.(2009 (3) TMI 243 - ITAT MADRAS-D), There should be uniformity in the ingredients of both the numerator and the denominator of the formula, Section 10-A is a beneficial section. It is intended to provide incentives to promote exports. If the export turnover in the numerator is to be arrived at after excluding certain expenses, the same should also be excluded in computing the export turnover as a component of total turnover in the denominator. The reason being the total turnover includes export turnover. The components of the export turnover in the numerator and the denominator cannot be different - Following decision of Commissioner of Income-tax Versus Tata Elxsi Ltd. [2011 (8) TMI 782 - KARNATAKA HIGH COURT] - Decided against Revenue. Deduction u/s 10A - Whether Commissioner of Income-tax (Appeals) has erred in holding that the claim under sec.10A shall be allowed before adjusting brought forward losses and unabsorbed depreciation - Held that:- Following decision of Changepond Technologies (P) Limited. Versus Assistant Commissioner Of Income-Tax [2008 (2) TMI 486 - ITAT MADRAS-A] - Decided against Revenue.
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