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2016 (10) TMI 1238 - AT - Income TaxDeduction u/s. 10A - disallowance made under the provisions of section 40(a)(ia) and 43B - Held that:- We find the Tribunal following the order of the Tribunal in assessee’s own case for A.Y. 2007-08 has decided the issue and directed the AO to allow deduction u/s.10A to the assessee on account of disallowance made under the provisions of section 40(a)(ia) and 43B. Addition u/s.92CA - Comparable selection - functinal dis-similarity - Held that:- Assessee is engaged in providing Software Development Services and Sales Support Services to Deere and Co., USA, thus companies functionally dissimilar with that of assessee and on account of different operating models/different business spheres and distinct mode of operation need to be deselected from list.
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