https://www.taxtmi.com/caselaws?id=176272 ITAT directed the AO/TPO to recompute the assessee's ALP for international transactions with the AE per the Bench's directions and to make adjustments if the margin differential exceeds the 5% bandwidth under proviso to section 92C(2). The Tribunal also held that for deduction under section 10A the telecom expense of Rs. 8,15,037 must be excluded from both export turnover and total turnover (following the HC principle), restoring parity and correcting the AO's earlier computation. The appeal was partly allowed with these directions. en-us Tue, 29 Jan 2013 00:00:00 +0530 Wed, 27 Aug 2025 17:31:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176272 ITAT directed the AO/TPO to recompute the assessee's ALP for international transactions with the AE per the Bench's directions and to make adjustments if the margin differential exceeds the 5% bandwidth under proviso to section 92C(2). The Tribunal also held that for deduction under section 10A the telecom expense of Rs. 8,15,037 must be excluded from both export turnover and total turnover (following the HC principle), restoring parity and correcting the AO's earlier computation. The appeal was partly allowed with these directions. Case-Laws Income Tax Tue, 29 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176272