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2020 (9) TMI 876 - HC - Income TaxRevision u/s 263 - Deduction u/s 10A - not excluding the expenditure incurred in foreign currency from export turnover for computing deduction - HELD THAT:- The assessee is engaged in the business of computer software development and services. The expenditure incurred in foreign currency on traveling, professional charges and onsite service charges are for development of software at clients site outside India, the assessee has neither rendered any technical services nor has earned any receipt from rendering technical services. Therefore, there is no need to exclude the expenditure incurred in foreign currency from the export turnover. See CHANGEPOND TECHNOLOGIES (P) LIMITED. [2008 (2) TMI 486 - ITAT MADRAS-A] and PATNI TELECOM (P) LIMITED. [2008 (1) TMI 452 - ITAT HYDERABAD-A] View taken by the Assessing Officer was a plausible view and the view taken by him cannot be said to be erroneous. Therefore, in view of well settled legal position, invocation of powers in the fact situation of the case under Section 263 of the Act could not have been held to be justified. - Decided in favour of assessee.
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