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ITAT allowed the assessee's appeal regarding section 80IA(10) deduction denial. The AO made a downward adjustment of Rs. 10.98 crore based on transfer pricing analysis of transactions between the eligible unit and its associated enterprise. However, ITAT held that existence of an "arrangement" between the deduction-seeking unit and AE is a mandatory precondition for invoking section 80IA(10) provisions. The AO failed to establish any such arrangement before referring the matter to TPO for arm's length price computation. Following precedents from Schmetz India and Mankind Pharma, ITAT ruled that without proving an arrangement, business transactions between eligible units and AEs do not constitute Specified Domestic Transactions under section 92BA, making transfer pricing analysis inapplicable and the adjustment unsustainable.
ITAT allowed the assessee's appeal regarding section 80IA(10) deduction denial. The AO made a downward adjustment of Rs. 10.98 crore based on transfer pricing analysis of transactions between the eligible unit and its associated enterprise. However, ITAT held that existence of an "arrangement" between the deduction-seeking unit and AE is a mandatory precondition for invoking section 80IA(10) provisions. The AO failed to establish any such arrangement before referring the matter to TPO for arm's length price computation. Following precedents from Schmetz India and Mankind Pharma, ITAT ruled that without proving an arrangement, business transactions between eligible units and AEs do not constitute Specified Domestic Transactions under section 92BA, making transfer pricing analysis inapplicable and the adjustment unsustainable.
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