Transfer Pricing (TP) adjustments - Transfer Pricing (TP)...
Section 10A Deductions Allowed for Additional Income in Modified Return u/s 92CD, Per Proviso to 92C(4.
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Income TaxDecember 4, 2019Case LawsAT
Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) - deduction u/s 10A cannot be disallowed in respect of additional income offered in the modified return as it is not a transfer pricing addition made by the AO but the additional transfer pricing income offered by the assessee in consonance with the APA with the CBDT.