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The HC upheld the appellate authorities' findings, holding that income computed pursuant to an APA executed under s.92CC is binding and, where the assessee voluntarily reported ALP-based adjustments in its return without enhancement by the AO under s.92C, the exemption under s.10AA remains available. The court reiterated that APAs remove valuation uncertainty for international transactions and are binding except in specified circumstances (change of law/facts, fraud/misrepresentation). The HC further held that the AO's adhoc 10% disallowance under s.14A lacked tangible basis; prior administrative acceptance of deletions and absence of prosecutable infirmity meant no substantial question of law arose for the appeals.
The HC upheld the appellate authorities' findings, holding that income computed pursuant to an APA executed under s.92CC is binding and, where the assessee voluntarily reported ALP-based adjustments in its return without enhancement by the AO under s.92C, the exemption under s.10AA remains available. The court reiterated that APAs remove valuation uncertainty for international transactions and are binding except in specified circumstances (change of law/facts, fraud/misrepresentation). The HC further held that the AO's adhoc 10% disallowance under s.14A lacked tangible basis; prior administrative acceptance of deletions and absence of prosecutable infirmity meant no substantial question of law arose for the appeals.
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