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2017 (9) TMI 1602 - AT - Income TaxTPA - selection of comparable - selection criteria - Held that:- Referring to software development and quality analysis services undertaken by Mentor India for Mentor Group as an independent contractor the companies functionally dissimilar with that of assessee need to be deselected from final list of comparable. Inclusion of communication charges in the gross turnover for the purpose of calculating the deduction u/s 10A - Held that:- As decided in assessee's own case we are inclined to accept the plea of the assessee that communication charges need to be excluded both from the export turnover as well as from the total turnover for the purpose of computing exemption u/s 10A and we direct the TPO/AO to recalculate the exemption by excluding the amount of impugned communication charges from both the total turnover as well as export turnover.
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