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TMI Blog2019 (4) TMI 1107X X X X Extracts X X X X X X X X Extracts X X X X ..... er For the Assessee : Shri Sagar Nagaraj, CA For the Revenue : Shri Smarak Swain, JCIT (DR) ORDER PER BENCH These two appeals are filed by the revenue and these two C. Os. Are filed by the assessee and these all are directed against two separate orders of ld. CIT(A)- 4, Bangalore both dated 02.01.2018 for Assessment Years 2012- 13 & 2013-14. 2. All these appeals and C.Os. were heard together ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd pointed out that total addition made by the AO is of Rs. 54,77,248/- only out of which the disallowance of Rs. 1,47,279/- is upheld by the ld. CIT(A) and only two disallowances are deleted by him of Rs. 52,84,163/- and Rs. 45,806/- total of Rs. 53,29,969/-. He submitted that for the deletion of both these disallowances, revenue is in appeal but the tax effect is less than Rs. 20 Lakhs and there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ure incurred in foreign currency towards telecommunication expenses&foreign travel expenses from the export turnover. 3. The Ld. CIT(A) ought to have appreciated that there is no provision in Sec. 10A which requires the concerned expenses, which are required to be reduced from the export turnover as per clause (iv) of the Explanation to Section 10A to be reduced from the total turnover also. 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Para 5.3 of his order, ld. CIT(A) has followed the judgement of Hon'ble Karnataka High Court rendered in the case of CIT Vs. Tata Elxsi Ltd. as reported in 349 ITR 98. He also submitted that now this issue is now covered in favour of the assessee by the judgement of Hon'ble Apex Court also having been rendered in the case of CIT Vs. HCL Technologies Ltd. as reported in [2018] 93 taxmann.com 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his view of Hon'ble Karnataka High Court has been approved by the Hon'ble Apex Court in the case of CIT Vs. HCL Technologies Ltd. (supra) and therefore, respectfully following these two judgments of Hon'ble Apex Court and of Hon'ble Karnataka High Court as noted above, we decline to interfere in the order of CIT (A) on this issue. 9. In the result, this appeal filed by the revenue is dism ..... X X X X Extracts X X X X X X X X Extracts X X X X
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