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Delhi HC upheld employee head count method for allocating cost towards STP unit for the purpose of computing benefit under Section 10A of the Income-tax Act,1961

Case Law Details

Case Name
Commissioner of Income Tax Vs EHPT India P. Ltd. (Delhi High Court)
Date of Judgement/Order
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CIT v. EHPT India P. Ltd.  (Delhi High Court)- Section 10A provides for deduction for profits derived from the export of software for a period of ten years. During the period of tax-holiday, it is desirable that the same method of computing the profits of the STP unit is adopted so that any distortion is avoided. We must however clarify that we are not to be understood as laying down as a proposition that in all cases arising under Section 10A, where the question of apportionment of common/indirect expenses between the taxable and the exempt units arises, the head-count method is the most app...
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