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TMI Blog2018 (7) TMI 486X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction u/s.10A of the Act, the controversy is no longer resintegra and is covered by the decision of the Division Bench of this Court in the case of M/s.Tata Elxsi Ltd., vs. Asst. Commissioner of Income Tax, [2015 (10) TMI 634 - KARNATAKA HIGH COUR] which has been affirmed by the Hon’ble Supreme Court in the case of Commissioner of Income-tax, Central – III vs. HCL Technologies Ltd., [2018 (5 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ucing those expenses that were reduced only from export turnover, to reduce from the total turnover also, without appreciating that there is no provision in section 10A to the effect that such expenses should also be reduced from the total turnover, as clause [ix] of the Explanation to section 10A provides that such expenses have to be reduced only from the export turnover? 3. Learned counsel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... below for ready reference:- 17. The similar nature of controversy, akin this case, arose before the Karnataka High Court in CIT v. Tata Elxsi Ltd. [2012] 204 Taxman 321/17/taxman.com 100/349 ITR 98. 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act are allowed only in Export Turnover but not from the Total Turnover then, it would give rise to inadvertent, unlawful, meaningless and illogical result which would cause grave injustice to the Respondent which could have never been the intention of the legislature. 20. Even in common parlance, when the object of the formula is to arrive at the profit from export business, expenses exclude ..... X X X X Extracts X X X X X X X X Extracts X X X X
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