11/13/2022 0 Comments Aris global software pvt ltd wikipediaLtd., 5/13 be attributed to it, the said ordinary meaning is to be in conformity with the context in which it is used. The issue before the Karnataka High Court was whether the Tribunal was correct in holding that while computing relief under Section 10A of the IT Act, the amount of communication expenses should be excluded from the total turnover if the same are reduced from the export turnover? While giving the answer to the issue, the High Court, inter-alia, held that when a particular word is not defined by the legislature and an ordinary meaning is to Date of Judgment 13-8-2018, ITA No.994 /2017 The Pr. The similar nature of controversy, akin this case, arose before the Karnataka High Court in CIT v. (supra), is quoted below for ready reference:-ġ7. The relevant portion of the judgment of the Honble Supreme Court in the case of HCL Technologies Ltd. The issue is covered by the decision of the Honble Supreme Court in the case of Commissioner of Income-tax, Central III vs. Ltd., 4/13 Regarding Substantial Question of Law No.2:Ĥ. The learned Tribunal, after discussing the rival contentions of both the Appellants-Revenue and Respondent-Assessee, has returned findings as under: Date of Judgment 13-8-2018, ITA No.994 /2017 The Pr. Tata Elxi even though the said decision has not reached finality and the assessing authority recomputed the 10A deduction as per the provisions of the Act?ģ. Whether on the facts and in the circumstances of the case, Tribunal is right in law in setting aside the recomputation of 10A deduction made by assessing authority by following the judgment of this Honble High Court in the case of CIT V/s. Whether on the facts and in the circumstances of the case, the Tribunal is right in law in excluding certain comparables on the basis of functional dissimilarity by following its earlier judgments which has not reached finality and even when the Transfer Pricing Officer has considered the comparables on the basis of qualitative and quantitative filters?Ģ. The substantial questions of law framed by the Revenue in the Memorandum of Appeal are as under: Date of Judgment 13-8-2018, ITA No.994 /2017 The Pr. for Appellants - Revenue This Appeal is filed by the Revenue purportedly raising the substantial questions of law arising from the Order of the Income Tax Appellate Tribunal, A Bench, Bangalore, in IT A No.94/Bang/2014 dated, relating to the Assessment Year 2009-10.Ģ.
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