Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (1) TMI 1734 - ITAT BANGALOREComputation of deduction u/s. 10A - exclusion of expenditure on travelling and communication from the total turnover as well as the export turnover - HELD THAT:- There should be uniformity in the ingredients of both the numerator and the denominator of the formula, Section 10-A is a beneficial section. It is intended to provide incentives to promote exports. If the export turnover in the numerator is to be arrived at after excluding certain expenses, the same should also be excluded in computing the export turnover as a component of total turnover in the denominator. See TATA ELXSI LTD.[2011 (8) TMI 782 - KARNATAKA HIGH COURT]. TP Adjustment - comparable selection - HELD THAT:- Assessee is a captive service provider engaged in the business of developing, testing, customizing and maintaining high quality software for its Associated Enterprises (AE) thus companies functionally dissimilar with that of assessee need to be deselected.
|