https://www.taxtmi.com/caselaws?id=216599 HC upheld the Tribunal's finding that the manufacturing division's high profits did not arise from an extraordinary arrangement with the foreign principal and therefore did not displace entitlement to deduction under Section 10A; differences between products of the manufacturing and trading divisions negated any collusive profit-shifting. Revenue's challenge was rejected as not showing perversity. The court also held that Section 10A operates as a deduction to be applied in computing business profits and should be allowed without setting off trading-unit losses at the Chapter VI-A stage. en-us Tue, 04 Sep 2012 00:00:00 +0530 Fri, 05 Sep 2025 12:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216599 HC upheld the Tribunal's finding that the manufacturing division's high profits did not arise from an extraordinary arrangement with the foreign principal and therefore did not displace entitlement to deduction under Section 10A; differences between products of the manufacturing and trading divisions negated any collusive profit-shifting. Revenue's challenge was rejected as not showing perversity. The court also held that Section 10A operates as a deduction to be applied in computing business profits and should be allowed without setting off trading-unit losses at the Chapter VI-A stage. Case-Laws Income Tax Tue, 04 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216599