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1 - 3 of 3 (0.15 seconds)M/S D.E. Shaw India Advisory Services ... vs Jcit, New Delhi on 4 September, 2017
36. The proviso to section 92CA(4) of the Act will apply only to adjustment
to transfer pricing made by the AO which is enumerated in Sl.No.(ii)
above and not to any other modes of determination of ALP. The decision
of the Pune Bench of ITAT in the case of Dar Al Handasah Consultants
(Shair & Partners) India Private Limited (supra) will be clearly
applicable to the facts of the present case."
C.I.T., Central-Iii, N.Delhi vs Hcl Technologies Ltd. on 24 April, 2018
7.1 After hearing rival submissions, we are of the view that
the above issue raised by the Revenue is no more res integra.
The Hon'ble Supreme Court in the case of CIT v. HCL
Technologies Ltd. reported in 404 ITR 719 had held that when
expenditure are reduced from the export turnover, the same
need to be reduced also from the total turnover while
calculating deduction u/s 10A of the I.T.Act. In view of the
dictum laid down by the Hon'ble Apex Court, ground No.1
raised in Revenue's appeal is rejected.
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