Section 10A of the Income-tax Act, 1961 – Exemption – Free trade zone – For computing deduction allowable u/s 10A, expenses reduced by the A. O. from export turnover should be reduced from total turnover also

Facts: In the appeal of Revenue, Grounds are in respect of T. P. issues and are in respect of the direction of the learned CIT (A) to the AO that the expenses reduced by the A.O. from export turnover for computing deduction allowable u/s 10A should be reduced from total turnover also.

Held, that grounds the appeal of the revenuer rejected because all these are in respect of T. P. issues which have attained finality as per MAP. Regarding the remaining grounds in the appeal of revenue also, we decline to interfere in the order of CIT (A) because the decision of CIT (A) on this issue i.e. reduction of certain expenses from Total Turnover for the purpose of deduction u/s 10A is in line with the judgment of Hon'ble Karnataka High Court rendered in the case of Tata Elxsi Ltd. (supra) – ITO Vs. AGILE SOFTWARE ENTERPRISES (P.) LTD. - [2020] 181 ITD 817 (ITAT-BANGALORE)