https://www.taxtmi.com/caselaws?id=359779 Where the record made no distinction between US and non-US ITES transactions and the MAP resolution fixed the arm's length margin for the substantial US component, the same margin was applied to the remaining non-US transactions as well. For section 10A computation, expenses excluded from export turnover had to be excluded from total turnover on the same principle of consistency, following binding jurisdictional precedent. The assessee succeeded on the transfer-pricing issue, while the Revenue failed on the section 10A issue. en-us Fri, 27 Apr 2018 00:00:00 +0530 Fri, 04 May 2018 08:50:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359779 Where the record made no distinction between US and non-US ITES transactions and the MAP resolution fixed the arm's length margin for the substantial US component, the same margin was applied to the remaining non-US transactions as well. For section 10A computation, expenses excluded from export turnover had to be excluded from total turnover on the same principle of consistency, following binding jurisdictional precedent. The assessee succeeded on the transfer-pricing issue, while the Revenue failed on the section 10A issue. Case-Laws Income Tax Fri, 27 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359779