2015 (4) TMI 1239

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....th Ms. Kavita Jha and Mr. Vaibhav Kulkarni, Advs. O R D E R 1. Admit. 2. Ms. Kavita Jha, Advocate accepts notice. 3. The following question of law arises for consideration : "Whether on facts and circumstances of the case, the Hon'ble ITAT has erred in holding that new unit is to be treated as a separate and independent unit for the purpose of computing deduction u/s 10A of the Act?" ....

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....see in regard to its transactions with the associated enterprise could have been subjected to adjustment. The ITAT was of the opinion that since the assessee was a service provider to its associated enterprise (AE) as well as other foreign customers or non- AEs, the suggestion that the non- AE transactions which reported lower margins and to be used for bench marking the AE transactions were accep....