Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (3) TMI 1322 - ITAT HYDERABADDisallowance of deduction u/s 10A - reduce communication charges, insurance & professional charges both from the Export turnover as well as total turnover - Held that:- Internet charges have to be excluded both from the export turnover as well as from the total turnover while computing deduction u/s 10A of the Act. The Hon’ble Bombay High Court in case of CIT vs. Gem Plus Jewellery (2010 (6) TMI 65 - BOMBAY HIGH COURT ) held that communication charges attributable directly to the export of article or thing outside India has to be excluded both from export turnover as well as total turnover while computing exemption u/s 10A of the Act. In view of the above, we uphold the order of the CIT(A) and dismiss the ground raised by the revenue. TP adjustment - selection of comparable - Held that:- As the revenue is objecting to exclusion of these 8 companies as comparables while the assessee is insisting to inclusion of four companies as comparables, we revert this issue back to the file of the TPO to re-do the issue after considering the submissions of the assessee and the assessee may be given opportunity of being heard in the matter. Accordingly, ground allowed for statistical purposes.
|