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2015 (10) TMI 2242 - AT - Income TaxTransfer pricing adjustment - selection of comparable - Held that:- Three companies, namely Aztec Software Ltd., Geometric Software Ltd. and Megasoft Ltd. and KALS Infosystems Ltd. and Accel Telemetrics Ltd. shall be excluded from the set of comparables for the software development services segment of the assessee. Tata Elxsi Ltd. and Lucid Software Ltd. excluded from the list of comparables for the software development services of the assessee. Infosys Technologies Ltd. be excluded from the set of comparables in the software development services segment of the assessee. Deduction under Section 10A - Held that:- Taking into consideration the decision rendered by the Hon'ble High Court of Karnataka in the case of 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 that communication charges and expenses incurred in foreign currency are to be excluded from both export turnover as well as total turnover while computing the deduction under Section 10A of the Act, as has been prayed by the assessee in its alternate plea Interest under Section 234B is consequential and mandatory and the Assessing Officer has no discretion in the matter.
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