Sec.10A- Communication cost in absence of profit element is to be excluded from total & export turnover

Brief of the case: In the case of Pegasystems Worldwide India Pvt. Ltd. Vs. ACIT Hyderabad Bench of ITAT directed the AO to reduce communication cost not only from export turnover but also from the total turnover for the purpose of computation of deduction as per Explanation 2 to section 10A. ITAT relied upon the case of ITO Vs. D.E. Block Indian Software Pvt. Ltd., wherein the tribunal considered the issue of adjustments of total turnover for the purpose of computing eligible profits U/s. 10A and held that the communication expenses need to be excluded from the exports as per the clause-IV of...