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2017 (11) TMI 1205 - AT - Income TaxEligibility of deduction 10A - Held that:- Identical issue came before this hon'ble Tribunal for the assessment years 2008-09 and 2009-10 in the own case of the assessee the assessee there is no dispute that it is a call centre engaged in managing accounts receivable and recovery. The calls are made by the "predictive dialer software" and after the call the inputs of the relevant information obtained from the data of the US financial institution is made in real time system which is transmitted to the customer outside India electronically using the internet system. In view of the explanation of the assessee, it is evident that customised electronic data is being transmitted outside India electronically. Assessing Officer has also mentioned that the assessee is using the internet lines for telephone calls to its international customer rather than traditional telephone lines. This observation also supports that the activities of the assessee are in the nature of call centre and therefore in our considered opinion, the assessee is entitled for deduction under section 10A of the Act. In prior assessment years, the Assessing Officer has accepted the claim of the assessee and deductions have been allowed. In the year under consideration, there is no change in the business activity of the assessee, thus, in our view, the principle of consistency also demand that this deduction should be allowed to the assessee.
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