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2017 (4) TMI 55 - ITAT DELHIAttributation of profits on offshore revenues - Held that:- Assessing Officer estimated taxable income in respect of offshore activities at 25% of the gross revenues. Admittedly, similar issue on the very same facts, has come before this Bench of the Tribunal in assessee’s own case for the assessment year 2006-07. The Tribunal had restored the issue to the file of the Assessing Officer with a direction that an afresh exercise be undertaken and attributation of profits on offshore revenues be determined. Consequent to such direction, the Assessing Officer, for the assessment year 2006-07, adopted 10% as the profit attributation on offshore revenues. As the Department has itself come to this decision on these very facts, we have no hesitation in applying the same percentage to the year under consideration. The Assessing Officer is directed to adopt 10% as the profit attributation on offshore revenues for the impugned assessment year 2007-08. Disallowances u/s 40(a)(i) and section 40(a)(ia) - Held that:- We set-aside the issue to the file of the Assessing Officer for fresh adjudication de-novo in accordance with law. The assessee states that its claim for deduction of expenses were disallowed u/s 40(a)(i) and section 40(a)(ia) in the earlier year and are being claimed in the current assessment year 2007-08. This claim has to be verified. Hence, we set aside the same to the file of the Assessing Officer. In the result, ground is allowed for statistical purposes.
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