2018 (4) TMI 1367

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..... R For Sri. K.R. Vasudevan Adv.)   B.S. PATIL J., JUDGMENT We have heard learned counsel for the parties. 2. Learned counsel appearing for both parties fairly submit that the matter is covered by a decision rendered by the co-ordinate Bench of this Court in the case of Commissioner of Income Tax and another vs. Tata Elixi Limited (2012) 349 ITR 98. 3. Challenge in this appeal,....

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....rendered by this Court in the case of Commissioner of Income Tax and another vs. Tata Elixi Limited reported in (2012) 349 ITR 98. A co-ordinate Bench of this Court has categorically laid down the law on the point at paragraph 17, as under; "From the aforesaid judgments, what emerges is that, there should be uniformity in the ingredients of both the numerator and the denominator of the formula,....

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....Even in the case of business of an undertaking, it may include export business and domestic business, in other words, export turnover and domestic turnover. The export turnover would be a component or part of a denominator, the other component being the domestic turnover. In other words, to the extent of export turnover, there would be a commonality between the numerator and the denominator of the....