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Showing contexts for: export surplus in Xl India Business Services Pvt. Ltd., ... vs Department Of Income Tax on 2 December, 2015Matching Fragments
15. That on facts and in law, the Learned AO/TPO/DRP have erred by not considering that the adjustment of the ALP, if any, should be limited to the lower end of the 5 percent as the appellant has the right to exercise this option under the proviso to Section 92C of the Act.
Part II- Corporate Tax Grounds
15. That on facts and in law, the Learned DRP/Assessing Officer erred in holding that the interest income of Rs.1,30,23,015/- eared in short term deposits made out of surplus funds from export activities of the Appellant, be treated as "Income from Other Sources" and not business income.