N.K. Saini, Accountant Member - This appeal by the assessee is against the order dated 06.10.2010 of the Assessing Officer passed u/s. 143(3) r.w. sec. 144C of the Income-tax Act, 1961 [hereinafter referred to as "the Act" in short"].

2. Following grounds have been raised in this appeal:

"Ground No. 1:

Treatment of Communication Expenses under section 10A: The learned Assessing Officer (hereinafter referred to as "AC") has grossly erred in law by not deducting the Communication Expenses amounting to Rs. 19,60,808/- from the 'Total Turnover' while reducing the same from 'Export Turnover' for the purposes of computing deduction under section 10A, thereby reducing the claim of deduction under section 10A by Rs. 1,46,131/- and the Hon'ble Dispute Resolution Panel (hereinafter referred to as "DRP") has erred in confirming the same.

Ground No. 2:

Re-computation of Arm's Length Price which has resulted in an addition of Rs. 98,20,024/-. Under this ground of appeal we have the following specific grounds of appeals:

a. The learned AC has erred in making a reference without recording any reasons based on which he reached the conclusion that it was 'expedient and necessary' to refer the matte