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M/s Multitech Software Systems India Pvt Ltd Versus Dy. Commissioner of Income Tax, Circle 12 (1) , Bangalore

2015 (10) TMI 2234 - ITAT BANGLORE

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 this Tribunal in the assessee's own case (201 .....

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son 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'), Bangalore issued under Section 144C of the Act d .....

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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 he proposed a T.P. Adjustment of ₹ 32, .....

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l 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 appeal before this Tribunal raising the fo .....

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ven 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 excluding expenses incurred in foreign currency t .....

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