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2018 (7) TMI 1415 - HC - Income TaxDeduction under Section 10-A - Held that:- Tribunal in ignorance of the aforesaid Proviso to Sub-section (4) of Section 92C of the Income Tax Act, but we do not find any binding character of such findings or observations because as far as the computation of income of the assessee is concerned, the Assessing Authority has not given any benefit of Section 10-A of the Act to the assessee with respect to Transfer Pricing Adjustments made in the Assessment Order. There is no reversal of such findings of the Assessing Authority by the Tribunal in the present case. Therefore, this observation cannot be said to be causing any prejudice to the Revenue in the present case. Therefore, no substantial question of law arises on the said submission of the learned counsel for the Revenue. As far as the other questions are concerned, we have already observed above that none of the questions actually gives rise to any substantial questions of law in the present appeal in view of our aforesaid judgment extracted above and therefore there is no merit in the present appeal of the Revenue. - Decided against revenue
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