2015 (10) TMI 2234

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....ondent : Shri G R Reddy, CIT (DR) ORDER Per Shri Jason P Boaz, AM. This appeal by the assessee is directed against the final order of assessment for Assessment Year 2006-07 passed under Section 143(3) rws 144C(13) of the Income Tax Act, 1961 (in short 'the Act') vide order dt.29.10.2010 in pursuance to the directions of the Dispute Resolution Panel ('DRP'), Bangalore issue....

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....Software development services 4,83,84,000 Reimbursement of expenses received 1,55,274. The TPO after examination of the matter, passed an order under Section 92CA of the Act dt.30.10.2009 wherein he proposed a T.P. Adjustment of Rs. 32,56,440 to the software development services segment of the assessee. 2.2 In consequence thereof, the Assessing Officer passed a draft assessment orde....

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.... in appeal before this Tribunal raising the following grounds:- "1. The Assessing Officer taking the natural meaning of the word Total Turnover for computing the deduction under Section 10A is against equity and law. 2. The Assessing Officer erred in not considering the Hon'ble ITAT order in the appellant's case pertains to the Assessment Year 2003-04 even though the same....

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....on under Section 10A of the Act. It was contended that admittedly, the assessee had computed its claim for deduction under Section 10A of the Act by excluding the aforesaid expenses from both export turnover as well as total turnover which was not accepted by the Assessing Officer who proceeded to recompute the deduction under Section 10A of the Act by reducing the aforesaid expenses incurred in f....