| |
| The Tax Publishers2020 TaxPub(DT) 0462 (Pune-Trib) INCOME TAX ACT, 1961
Section 10A
When object of formula in section 10A for computation of deduction is to arrived at profit from export business, expenses excluded from export turnover have to be excluded from total turnover also otherwise, any other interpretation makes formula unworkable and absurd and hence, such deduction would be allowed from total turnover in same proportion as well.
|
Deduction under section 10A - Computation of total turnover - Treatment of expenses excluded from export turnover -
Assessee claimed deduction under section 10A. AO re-computed amount deductible after excluding communication expenses, insurance and travel expenses from export turnover, however, without reducing the same from total turnover.Held: When object of formula in section 10A for computation of deduction is to arrive at profit from export business, expenses excluded from export turnover have to be excluded from total turnover also otherwise, any other interpretation makes formula unworkable and absurd and hence, such deduction would be allowed from total turnover in same proportion as well.
Followed:CIT v. HCL Technologies Ltd. (2018) 404 ITR 719 (SC) : 2018 TaxPub(DT) 2138 (SC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2009-10
INCOME TAX ACT, 1961
Section 10A
 SUBSCRIBE FOR FULL CONTENT
|