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2018 (7) TMI 1402 - AT - Income TaxTPA - comparable selection criteria - Held that:- Considering assessee to be an ITES provider, companies functionally dissimilar with that of assessee need to be deselected from final list. Deduction u/s 10A - Held that:- While computing the deduction u/s 10A of the Act, if any expenditure is to be excluded from the export turnover, then the same is to be excluded from the total turnover as well. AO is bound to give the benefit of variation (+_)5% margin under the proviso to sub-section (2) of section 92C of the Act and if the assessee’s margin is within (+_)5% of the average margin of the comparables, then no adjustment is to be made. The AO is directed accordingly.
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