9911796707
TMI Blog2022 (3) TMI 648X X X X Extracts X X X X X X X X Extracts X X X X ..... iary of Romax Technology Ltd., UK. - HELD THAT:- AO's calculation of excess deduction u/s. 10A is based on the Arm's Length price based profit of the IT Enabled service rendered vis- -vis the assessee's actual profit from such services. It is pertinent to mention that the assessee's Associated Enterprises, namely, Romax Technology Ltd., UK is not chargeable to tax in India - assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 - SHRI R.S. SYAL, VICE PRESIDENT For the Appellant : Piyush Kumar Singh Yadav For the Respondents : Sharad Shah ORDER Per R.S. Syal, VP This appeal by the Revenue is directed against the order passed by the CIT(A) on 02-01-2017 in relation to the assessment year 2009-10. 2. It is a recalled matter inasmuch as the earlier order passed by the Tribunal on 14-08-2018 was r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ductible u/s. 10A of the Act. The Assessing Officer (AO) allowed the same in scrutiny assessment. Thereafter, the proceeding were taken up pursuant to notice u/s. 148 on the ground that excess deduction was allowed u/s. 10A of the Act amounting to ₹ 35,27,217/-. Such a view was premised on the understanding that the assessee computed the Arm's Length Price of the international transactio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngth price based profit of the IT Enabled service rendered vis- -vis the assessee's actual profit from such services. It is pertinent to mention that the assessee's Associated Enterprises, namely, Romax Technology Ltd., UK is not chargeable to tax in India. In other words, the assessee offered suo motu higher income in its hands, which was albeit deductible u/s. 10A, without conferring any ..... X X X X Extracts X X X X X X X X Extracts X X X X
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