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2018 (2) TMI 1282 - AT - Income TaxAddition on account of arm’s length price adjustment - selection of comparable - Held that:- The assessee is responsible for processing informations contained in the resumes according to the pre-set criteria developed by AEs and including it into Search Palace. The database of resumes and Search Palace are accessible by AE’s global operations. The assessee is also responsible for ensuring quality and consistency in data entry for Search Palace, database, minimize duplication of effort and reuse of information and to move into more proactive research work for business development. In addition to maintain data for the Search Palace database, the assessee also supports its AE’s in performing adhoc research work and news alerts, thus companies functinally dissimilar with that of assessee need to be deselected from final list. Deduction u/s 10A - action of the AO in excluding the foreign currency expenditure towards communication charges and database expenses - from the export turnover without reducing the same from the total turnover - Held that:- Respectfully following the aforesaid referred to order in the case of DCIT Vs Global Logic India (P) Ltd.[2012 (12) TMI 1018 - ITAT DELHI] we direct the AO to reduce the aforesaid expenses out of the export turnover as well as the total turnover while working out the deduction u/s 10A
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