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Assessee eligible for sec. 10A deduction on additional income offered conforming to advance pricing agreement

December 5, 2019[2019] 112 taxmann.com 82 (Pune - Trib.)
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TRANSFER PRICING : Deduction under section 10A cannot be disallowed in respect of additional income offered in modified return as it is not a transfer pricing addition made by Assessing Officer but additional transfer pricing income offered by assessee in consonance with APA with CBDT, thus, proviso to section 92C(4) does not debar deduction under section 10A on additional income in assessment under section 92CD; assessment under section 92CD provides for granting deduction under section 10A

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