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TMI Blog2008 (8) TMI 917X X X X Extracts X X X X X X X X Extracts X X X X ..... een filed by the assessee against the order of CIT(A)-II, Bangalore dated 19.9.2007 on the following grounds; 1. The order passed by DCIT u/s 143(3) of the Act and the learned CIT(A) u/s. 250 of the Act are bad in law and on facts. 2. In the facts and circumstances, the CIT(A) erred in holding that for the purpose of computing deduction u/s 10B of the Act, an adjustment needs to be made to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case of the M/s Seva Systems Pvt.Ltd., in ITA No.4019B)/2007, wherein the Tribunal in paras 6,7,8,9 and 10 held as under; 6. We have heard the rival submissions and perused the material available on record. On a careful perusal of the facts and circumstances relating to agitation by the assessee before us, the facts of the case of the assessee's case, leading to claim of deduction u/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o note that once the expenses incurred are for the business, it will be nobody's case to disallow the same as having not been incurred for rendering the services as a call center by the assessee, who has claimed deduction u/s 10A, which the AO verified as another provision of section 10A compared to section 80HHE. Once this exercise has been undertaken, it becomes important to consider the ove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expenses which have been estimated at 70% by the learned CIT(A) is pertaining to having been incurred for the export turnover be estimated at 50% in view of the incoming and outgoing expenses continuously from a call center. In other words, 75% of the telecommunication expenditure as estimated by the learned CIT(A) is reduced to 50% to be considered as attributable to the delivery of software out ..... X X X X Extracts X X X X X X X X Extracts X X X X
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