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2020 (12) TMI 924 - AT - Income TaxEligibility for deduction u/s 10A - HELD THAT:- In principle, the deduction u/s 10A is allowable because this is offered by the assessee itself as Voluntary T P Adjustment and therefore, this issue in principle is covered in favour of the assessee by the tribunal order cited by the learned AR of the assessee as noted above. But on this factual aspect about Prior Period Expenses for F. Y. 2008 – 09 reported by the assessee in Schedule 8 of the Audited Accounts for F. Y. 2009 – 10 this is not clear as to whether these expenses or any part of these expenses is related to Prior Period income of ₹ 5,42,11,607/- reported in same Schedule 8 of the Audited Accounts for F. Y. 2009 – 10 because if the same is related then the actual income on this account will be less and then only actual such income can be considered for deduction u/s 10A. On this aspect, neither any detail is made available before us nor there is any finding of AO or CIT (A). Hence, we restore this matter to AO for fresh decision.
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