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2018 (11) TMI 1559
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....BY SRI T. SURYANARAYANA, ADVOCATE) RAVI MALIMATH, J., J U D G M E N T Heard. 2. The appeal was admitted for consideration of the following substantial questions of law: "1. Whether the Tribunal was correct in holding that payment of Rs. 10,37,42,694/- made to M/s. AT & T and M/s. MCI to utilize its bandwidth did not attract deduction of TDS u/s.195 of the Act and conse....
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....ommunication charges of Rs. 10,37,42,694/- was liable to be reduced from both export turnover as well as total turnover for the purpose of computation of deduction u/s. 10A of the Act, even though the definition in the said section did not contemplate such reduction in the total turnover? 5. Whether the Tribunal was correct in holding that for the purpose of computation of deduction u/s. 80HHE ....
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.... of the aforesaid order of this Court, the same is remanded to the Tribunal for a fresh consideration in terms of the direction issued in the earlier case of the assessee itself. 5. The fourth substantial question of law is covered by the judgment of the Hon'ble Supreme Court in the case of COMMISSIONER OF INCOME TAX, CENTRAL-III vs. HCL TECHNOLOGIES LTD. reported in (2018) 93 Taxmann.com 33 (S....