2020 (2) TMI 933

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..... ncluded for both these two years in respect of assessee company s transaction with AE in US. Hence, the TP grounds raised by both sides in these two years do not survive and the same are rejected. Computation of deduction u/s 10A - HELD THAT:- Expenses reduced from export turnover should be reduced from total turnover also for the purpose of computing deduction allowable to the assessee under sect .....

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..... 2011-12 which are passed by AO under section 143(3) r.w.s. 144C of the IT Act, 1961as per the directions of DRP. 2. These appeals were heard together and are being disposed of by way of this common order for the sake of convenience. 3. In the course of hearing, it was agreed by both sides that in these 2 years, MAP has been concluded and therefore, TP grounds raised by both parties in these two ye .....

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..... issue in the Revenue s appeal for Assessment Year 2011-12 as per grounds 8 and 9 and as per these grounds, this is the grievance of the Revenue that DRP was not right in holding that expenses reduced from export turnover should be reduced from total turnover also for the purpose of computing deduction allowable to the assessee under section 10A of the IT Act, 1961. As per this judgment of Hon ble .....

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