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    <title>2015 (7) TMI 492 - ITAT BANGALORE</title>
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    <description>The Tribunal upheld the use of the Cost Plus Method (CPM) for determining the arm&#039;s length price (ALP) and the selection of comparables based on product similarity. Adjustments to export turnover included excluding telecommunication expenses from both export and total turnover and including profits from trading activities in the eligible profits for deduction under section 10A. The issue of depreciation on plant and machinery purchased from M/s. Elpro International Ltd. was remanded to the CIT(A) for a decision consistent with earlier years&#039; appeals. The revenue&#039;s appeal was dismissed, while the assessee&#039;s appeals for the assessment years 2004-05 and 2005-06 were partly allowed.</description>
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