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2018 (7) TMI 2282 - HC - Income TaxTP Adjustment - excluding the comparables such Kals Information Systems Ltd and Bodhtree Consulting Ltd - HELD THAT:- KALS Information Systems Ltd. and Bodhtree Consulting Ltd. are functionally dissimilar to that of the assessee and hence it is not to be regarded as a comparable. See M/S. CISCO SYSTEMS (INDIA) PRIVATE LTD.[2014 (11) TMI 849 - ITAT BANGALORE] Nature of expenses - software expenses - revenue or capital expenditure - HELD THAT:- This Court in the case of Commissioner of Income Tax vs. IBM India Ltd.,[2013 (10) TMI 1225 - KARNATAKA HIGH COURT] and answered the substantial question of law in favour of the Assessee and against the Revenue, treating the software expenses as revenue expenditure.
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