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2022 (2) TMI 710 - HC - Income TaxDeduction u/s 10A - excluding the foreign Travel Expenditure and Telecommunication expenses both from the Export turnover and also from the Total turnover while computing deduction - HELD THAT:- Issue decided in favour of assessee as relying on HCL TECHNOLOGIES LTD. [2018 (5) TMI 357 - SUPREME COURT] if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under Section10A of the IT Act are allowed only in Export Turnover but not from the Total Turnover then, it would give rise to inadvertent, unlawful, meaningless and illogical result which would cause grave injustice to the Respondent which could have never been the intention of the legislature. Even in common parlance, when the object of the formula is to arrive at the profit from export business, expenses excluded from export turnover have to be excluded from total turnover also. Otherwise, any other interpretation makes the formula unworkable and absurd. Hence, we are satisfied that such deduction shall be allowed from the total turnover in same proportion as well. - Decided against revenue.
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