DCIT, BANGALORE vs. M/S GE INDIA EXPORT PVT. LTD.,, BANGALORE

ITA 253/BANG/2016Status: DisposedITAT Bangalore27 January 2026AY 2011-12Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal admitted additional grounds of appeal concerning transfer pricing. It held that telecommunication expenses excluded from export turnover must also be excluded from total turnover for Section 10A deduction, following Supreme Court precedent.

What were the facts?

The assessee, engaged in software development and engineering services, disputed transfer pricing adjustments and the exclusion of telecommunication expenses from total turnover for Section 10A deduction. The TPO made an upward adjustment, and the DRP upheld some of the TPO's decisions.

What were the issues?

Whether telecommunication expenses excluded from export turnover should also be excluded from total turnover for Section 10A deduction, and issues related to transfer pricing adjustments and comparable selection.

Which sections of the Income-tax Act were involved?

Section 10A,Section 143(3),Section 144C(5),Section 254

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, ‘C’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. Viyushti, Shri Aditya Matulli, Advocate
For Respondent: Dr. KJ Divya, CIT (DR)
Hearing: 09.12.2025Pronounced: 27.01.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

IT(TP)A No.253 & 293/Bang/2016 These cross appeals at the instance of the assessee and revenue are directed against the assessment order passed by the Ld. TPO u/s 143(3) r.w.s. 144C(13) of the Act., in pursuant to the directions of the Ld. DRP issued u/s 144C(5) of the

The order continues below.

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