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2018 (5) TMI 343 - AT - Income TaxTPA - margin adopted for US transactions - mark-up applied in the MAP Resolution for USA transactions - Held that:- Following the decision in the case of J P Morgn Services Pvt. Ltd. (2015 (12) TMI 296 - ITAT MUMBAI) we hold that the margin adopted for US transactions, in ITES Segment, as was decided in the MAP Resolution, shall be adopted for non-US transactions as well. The TPO/A.O. is directed accordingly. Deduction u/s.10A - Held that:- The issue is squarely covered by the judgment of the Hon'ble jurisdictional High Court in the case of Tata Elxsi Ltd. (2011 (8) TMI 782 - KARNATAKA HIGH COURT ) in which it has been held that if certain expenses are excluded from export turnover, then the same should also be excluded from the total turnover.
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