ASSISTANT COMMISSIONER OF INCOME TAX vs SRA SYSTEMS LTD.

Authority: ITAT Tribunal/Court: Chennai Date: 2013-01-08 AY: 2003-04, 2004-05 Section: 143(3), 147, 92CA, 10A Acts: Income Tax Act 1961, Income Tax Rules Result: Assessee Citation: (2015) 153 ITD 0338 (Chennai) : (2013) 022 ITR 0205 Justices: Dr. O. K. Narayanan, VP & S. S. Godara, JM. Appeal No: ITA Nos. 528(Mds)/2009 & 938(Mds)/2008 (C.O. No.84(Mds)/2009)
Whether the Transfer Pricing Officer (TPO) was justified in rejecting the assessee's selection of comparable companies for determining Arm's Length Price (ALP) without providing reasons --- Held No. Whether the assessee is entitled to exemption under section 10A of the Income Tax Act --- Held Yes. Whether expenses incurred for development of software are allowable as revenue expenditure --- Held Yes. Whether delay charges related to dividend tax and TDS are deductible --- Held No.

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