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2021 (10) TMI 1098 - AT - Income TaxTP Adjustment - comparable selection - turnover of the companies sought for exclusion is more than 200 crores - HELD THAT:- As considering 10 times to 1/10 of the turnover the alleged comparable is much more than the turnover of assessee. We note that, assessee in Acusis Software India Pvt.Ltd [2018 (8) TMI 1885 - KARNATAKA HIGH COURT] AND Autodesk India Pvt.Ltd [2018 (7) TMI 1862 - ITAT BANGALORE] were captive service provider like assessee before us. Respectfully following the same we direct the Ld.TPO to exclude the comparable’s alleged hereinabove for exclusion. Computing deduction under section 10AA - As reduced communication expenses and travelling and conveyance expenses incurred from the export turnover - HELD THAT: - We respectfully following the view taken by Hon’ble Supreme Court direct the Ld.AO to recompute deduction under section 10AA of the Act in accordance with the principles laid down in case of CIT vs HCL Technologies [2018 (5) TMI 357 - SUPREME COURT]
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