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TMI Blog2017 (11) TMI 174X X X X Extracts X X X X X X X X Extracts X X X X ..... me Tax-VI (2016 (8) TMI 166 - DELHI HIGH COURT). The Court accordingly declines to frame the question. Particular item is not part of 'Export Turnover' when it cannot constitute a part of 'Total Turnover' as well - whether ITAT was correct in law in holding that if a particular item is not part of 'Export Turnover' when it cannot constitute a part of 'Total Turnover' as well? - Held that:- Havi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Del/2016 for the Assessment Year (AY) 2011-12 read as under: A. Whether on facts and in the circumstances of the case the Ld. ITAT was correct in law in holding that the Assessee was not liable to withhold tax under section 195 of the Act on payments made by it to Steria France for management services fee and consequently deleting the disallowance made by Ld. A0 under Section 40(a)(i) of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Having perused the said judgments, the Court is not persuaded to take a view different from that taken by the ITAT or the Bombay High Court that the total turnover always includes the export turnover and that if a particular item is not part of the export turnover, it cannot constitute a part of the total turnover either. 5. The appeal is, accordingly, dismissed. - - TaxTMI - TMITax - Inco ..... X X X X Extracts X X X X X X X X Extracts X X X X
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