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2015 (10) TMI 2234 - ITAT BANGLORE

2015 (10) TMI 2234 - ITAT BANGLORE - TMI - Deduction under Section 10A - assessee challenge the action of Assessing Officer and the DRP in excluding expenses incurred in foreign currency towards telecommunication and travel expenses towards delivery of software from export turnover while computing the deduction under Section 10A - Held that:- Taking into consideration the decision rendered in the case of Tata Elxsi Ltd. (2011 (8) TMI 782 - KARNATAKA HIGH COURT) and of the co-ordinate bench of th .....

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Dated:- 18-9-2015 - Vijaypal Rao, JM And Jason P Boaz, AM, JJ. For the Petitioner : Shri A S Sriraman, Adv For the Respondent : Shri G R Reddy, CIT (DR) ORDER Per Shri Jason P Boaz, AM. This appeal by the assessee is directed against the final order of assessment for Assessment Year 2006-07 passed under Section 143(3) rws 144C(13) of the Income Tax Act, 1961 (in short 'the Act') vide order dt.29.10.2010 in pursuance to the directions of the Dispute Resolution Panel ('DRP'), Banga .....

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Since the assessee had reportedly entered into the following international transactions, the Assessing Officer made a reference to the Transfer Pricing Officer ('TPO') for determination of the Arm's Length Price ('ALP') thereof. International Transactions Amount (Rs.) Provision of Software development services 4,83,84,000 Reimbursement of expenses received 1,55,274. The TPO after examination of the matter, passed an order under Section 92CA of the Act dt.30.10.2009 wherein h .....

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t dt.29.9.2010 allowing the assessee partial relief. In pursuance thereof, the Assessing Officer passed the final order of assessment under Section 143(3) rws 144C(13) of the Act vide order dt.29.10.2010 wherein the income of the assessee was computed at ₹ 38,10,260 in view of the restriction of the assessee's claim for deduction under Section 10A of the Act to ₹ 1,78,17,937. 3. Aggrieved by the final order of assessment for Assessment Year 2006-07, dt.29.10.2010, the assessee in .....

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he natural meaning for the Total Turnover even though the Hon'ble ITAT have explicitly passed an order in the appellant's own case is against equity and law. 4. The appellant craves leave to adduce additional ground/arguments at the time of hearing." 4. Ground Nos.1 to 4 : Deduction under Section 10A of the Act. 4.1 In these grounds, the sole issue of dispute in this appeal, the assessee challenge the action of the authorities below (i.e. the Assessing Officer and the DRP) in exclud .....

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