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2019 (11) TMI 1023 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee as engaged in the business of providing Capital Software Services and Marketing Support Services to its Associated Enterprises (AEs) need to be deselected from final list. Deduction u/s 10A - claim of expenditure is foreign currency from export turnover and not from total turnover - HELD THAT:- Following the aforementioned decision of the Hon’ble High Court of Karnataka in the case of Tata Elxsi Ltd. [2011 (8) TMI 782 - KARNATAKA HIGH COURT] we find the ld. CIT (Appeals) has relied on judicial decisions and we uphold the order of the learned CIT (Appeals) in directing the Assessing Officer to reduce the expenditure from both export turnover and total turnover for the purpose of computing the deduction under section 10A of the Act and dismissed the grounds of appeal of the Revenue.
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