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PR Commissioner of Income Tax – 4 Versus Granada Services Pvt. Ltd.

2015 (8) TMI 662 - DELHI HIGH COURT

Eligibility for deduction under Section 10A - expenses in foreign exchange and insurance and communication expenses which were not excluded from the export turnover within the meaning of Explanation 2 (iv) to Section 10A - ITAT noticed that since the .....

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charges or insurance attributable to the delivery of the articles or things or computer software outside India or expenses, if any, incurred in foreign exchange in providing the technical services outside India were not to be included in export turn .....

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f the Revenue. Decided against revenue. - ITA No. 446/2015 - Dated:- 6-8-2015 - S. Muralidhar And Vibhu Bakhru, JJ. For the Petitioner : Mr. Kamal Sawhney, Sr standing counsel with Mr Raghuvendra Singh, Adv. For the Respondent : None ORDER 1. This ap .....

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ssee was engaged in the business of Business Process Outsourcing ('BPO') which provides back office services to its overseas clients. The unit of the Assessee was eligible for deduction under Section 10A of the Act. During the course of the a .....

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t. The AO in the order dated 28th November 2011 observed that the Assessee had also incurred the insurance and communication expenses which had also not been excluded from the computation of export turnover. 3. Aggrieved by the said order, the Assess .....

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ver also. The CIT (A) held that the action of the AO was not justified and that none of the expenses identified by the AO ought to have been excluded from export turnover for computing deduction under Section 10A of the Act. The CIT (A) further held .....

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ncurred expenses in foreign exchange for providing technical services outside India, those were not included in the export turnover. The ITAT also noticed that Explanation 2 (iv) to Section 10A of the Act provides that freight, telecommunication char .....

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