TaxTMI 
TaxTMI 
2010 (9) TMI 108
X X X X Extracts X X X X
X X X X Extracts X X X X
....Kavita Jha, Advocates A.K. SIKRI, J. (ORAL) 1. Admittedly respondent-assessee is engaged in the business of manufacture and export of computer software. It operates through the STP units located at Noida, Gurgaon and Chennai. In the Income-tax return filed for the assessment year 1999-2000, it had claimed certain incomes as exempt from tax under Section 10A of the Income-Tax Act. These included....
X X X X Extracts X X X X
X X X X Extracts X X X X
....as allowed the same. These are as under:- (i) Amount of Rs. 11.76 lakhs received by the assessee as reimbursement of expenses incurred in obtaining ISO certification. (ii) Reimbursement of Rs. 9,00,215/- relating to rent satellite charges, printing, stationery, etc. from HCL Technologies Ltd. (iii) Corporate charges amounting to Rs. 20 lakhs earned from the sister concern, i.e., HCL Technologie....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ify for exemption under Section 10A of the Act. Similar is the position in respect of other two claims which are dealt with by the ITAT in the following manner:- "7. We have considered rival submissions. The assessee company, part of HCL Group of Company, incurred certain expenses on behalf of HCL Technologies Ltd. The same were reimbursed in the form of corporate charges. Similarly, the assessee....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ngly, Ground Nos. 6, 9 & 10 are ruled in favour of assessee." 4. Another issue relates to lease rent payment of Rs. 2,04,400/- to Noida authorities. The dispute was as to whether it is to be treated as revenue expenditure or capital expenditure. The assessing officer had disallowed the same treating it as capital expenditure. Reversing this decision, ITAT has allowed it as revenue expenditure in ....