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    <title>2017 (12) TMI 862 - ITAT HYDERABAD</title>
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    <description>STPI registration as a 100% export oriented undertaking was treated as sufficient for section 10B eligibility, so separate approval by the Board under the Industries (Development and Regulation) Act was not required and deduction was allowed. For section 10A computation, communication charges and bandwidth/VOIP charges excluded from export turnover were also required to be excluded from total turnover to preserve the deduction formula, in line with the settled ratio. On transfer pricing, the arm&#039;s length margin for software development services had to be recomputed after excluding depreciation as directed by the DRP, and the matter was restored for recomputation. No interest was imputed on receivables from associated enterprises on the facts found, as the assessee had not charged such interest and receipts were realised within a reasonable period.</description>
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      <description>STPI registration as a 100% export oriented undertaking was treated as sufficient for section 10B eligibility, so separate approval by the Board under the Industries (Development and Regulation) Act was not required and deduction was allowed. For section 10A computation, communication charges and bandwidth/VOIP charges excluded from export turnover were also required to be excluded from total turnover to preserve the deduction formula, in line with the settled ratio. On transfer pricing, the arm&#039;s length margin for software development services had to be recomputed after excluding depreciation as directed by the DRP, and the matter was restored for recomputation. No interest was imputed on receivables from associated enterprises on the facts found, as the assessee had not charged such interest and receipts were realised within a reasonable period.</description>
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