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2020 (3) TMI 228 - AT - Income TaxDeduction u/s 10A - HELD THAT:- In the present case, the Assessing Officer has not proved that any arrangement had been arrived between the parties which resulted in higher profits. Consequently, the re-working of the profits by Assessing Officer by invoking section 10A r.w.s. 80- IA(10) of the Act is not justified. The action of the Assessing Officer to restrict the deduction u/s 10A is hereby set-aside. Thus, assessee succeeds on this aspect. TP Adjustment - ordinary profit earned by the assessee be that of comparable companies - HELD THAT:- Assessee reported international transactions regarding system integration division and bifurcated the same in two sub-business segments namely IS-Infra and Balance Systems. The Balance Systems was benchmarked with external comparables to show arm‟s length price and with internal TNMM comparables for IS-Infra Business thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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