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2018 (4) TMI 567 - AT - Income TaxEligibility for deduction u/s.10A on profits and gains as are derived from the export of computer software - Held that:- Taking into consideration the decision rendered in the case of CIT v. Tata Elxsi Ltd [2011 (8) TMI 782 - KARNATAKA HIGH COURT] we are of the view that the order of the CIT(A) directing the AO to exclude communication charges and travelling and conveyance expenses both from export turnover and total turnover, is just and proper and calls for no interference. Addition made consequent to determination of Transfer Price by the Transfer Pricing Officer(TPO), which addition was deleted by the DRP in its directions on the adjustment to Arm’s Length Price (ALP) - Held that:- Assessee in into providing software development services by the Assessee to its AE thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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