https://www.taxtmi.com/caselaws?id=233378 ITAT Hyderabad (AT) held that the Assessing Officer's invocation of s.10A(7) r.w.s.80IA(10) to recharacterize profits-by substituting the assessee's CUP-based ALP with a TNMM outcome and denying the s.10A deduction-was unsustainable. The Tribunal found no arranged transaction or profit-shifting with the AE, accepted that higher profits arose from efficient operations and that receipts were at arm's length, allowed the assessee's grounds, and directed the AO to treat declared profits as ordinary and permit the s.10A deduction without further adjustment. en-us Thu, 31 Jan 2013 00:00:00 +0530 Fri, 05 Sep 2025 12:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233378 ITAT Hyderabad (AT) held that the Assessing Officer's invocation of s.10A(7) r.w.s.80IA(10) to recharacterize profits-by substituting the assessee's CUP-based ALP with a TNMM outcome and denying the s.10A deduction-was unsustainable. The Tribunal found no arranged transaction or profit-shifting with the AE, accepted that higher profits arose from efficient operations and that receipts were at arm's length, allowed the assessee's grounds, and directed the AO to treat declared profits as ordinary and permit the s.10A deduction without further adjustment. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233378