TMI Blog2021 (3) TMI 1212X X X X Extracts X X X X X X X X Extracts X X X X ..... ther exemption under section 10A of the Act should not be computed after excluding telecommunication expenses and foreign currency expenditure from the export turnover - HELD THAT:- In view of the decision rendered in HCL COMNET SYSTEMS SERVICES LTD. [ 2021 (3) TMI 1182 - DELHI HIGH COURT] These questions of law as suggested by the revenue cannot be entertained. In brief, the questions of law as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ws: a) Whether in the facts and circumstances of the case and in law. ITAT misinterpreted the scope of Section 14A(1) of the Act and errored in holding that Section 14(A) can only be invoked if the Respondent has earned exempted income during the assessment year ignoring the fact that Section 14A doesn t lay down such requirement and the only precondition for invoking Section I4A is that ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se fee paid to the Department of telecommunication by the assessee, which clearly established that the expenditure was a capital expenditure and wrongly relied upon the decision in CIT V Bharti Hexacom Limited 221 Taxman 323(Delhi)? e) Whether in the facts and circumstances of the case and in law. ITAT errored in holding that the exemption under section 10A of the Act should not be computed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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