Search Results Page
Search Results
1 - 5 of 5 (0.20 seconds)
Principal Commissioner Of Income Tax - 4 vs M/S Winphoria Networks India Pvt Ltd on 28 August, 2018
cites
Section 10A in The Income Tax Act, 1961 [Entire Act]
C.I.T., Central-Iii, N.Delhi vs Hcl Technologies Ltd. on 24 April, 2018
Respectfully following the ratio of the
decision in the case of M/s. NTT DATA Global
Delivery Services Ltd., [supra] we uphold the
order of the TPO/AO in including the following
comparable companies:
The Commissioner Of Income Tax vs M/S. Tata Elxsi Ltd on 30 August, 2011
"17. The similar nature of controversy, akin
this case, arose before the Karnataka High Court
in CIT v. Tata Elxsi Ltd. [2012] 204 Taxman
321/17/taxman.com 100/349 ITR 98. The issue
before the Karnataka High Court was whether
the Tribunal was correct in holding that while
computing relief under Section 10A of the IT Act,
the amount of communication expenses should be
excluded from the total turnover if the same are
reduced from the export turnover? While giving
the answer to the issue, the High Court, inter-alia,
held that when a particular word is not defined
by the legislature and an ordinary meaning is to
be attributed to it, the said ordinary meaning is to
be in conformity with the context in which it is
used. Hence, what is excluded from 'export
turnover' must also be excluded from 'total
turnover', since one of the components of 'total
turnover' is export turnover. Any other
interpretation would run counter to the legislative
intent and would be impermissible.
The Income Tax Act, 1961
1