https://www.taxtmi.com/caselaws?id=207725 HC upheld the Tribunal's acceptance of the assessee's head-count method for apportioning common/indirect expenses between STP and domestic units for computing exemption under s.10A. The Court applied the rule of consistency, holding that since the department had consistently accepted this method in earlier years, the AO could not reject it for the years in appeal without demonstrating distortion of profits or statutory violation. Turnover-based allocation, though possibly preferable in manufacturing, was not mandated, and head-count was a plausible method in a service industry. Finding no perversity in the Tribunal's reasoning or factual conclusions, HC dismissed the Revenue's appeal. en-us Wed, 14 Dec 2011 00:00:00 +0530 Wed, 03 Dec 2025 13:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207725 HC upheld the Tribunal's acceptance of the assessee's head-count method for apportioning common/indirect expenses between STP and domestic units for computing exemption under s.10A. The Court applied the rule of consistency, holding that since the department had consistently accepted this method in earlier years, the AO could not reject it for the years in appeal without demonstrating distortion of profits or statutory violation. Turnover-based allocation, though possibly preferable in manufacturing, was not mandated, and head-count was a plausible method in a service industry. Finding no perversity in the Tribunal's reasoning or factual conclusions, HC dismissed the Revenue's appeal. Case-Laws Income Tax Wed, 14 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207725