https://www.taxtmi.com/caselaws?id=251102 ITAT (Del) held partly for the assessee, allowing the contested deduction under s.10A for AY 2009-10. The Tribunal found s.80IA(10) permits scaling down profits if an arrangement with a related person produces extraordinary profits, but the AO failed to demonstrate any such arranged course of transactions with overseas AEs; mere higher profits were insufficient. The proviso to s.80IA(10) (w.e.f. 1.4.2013) was inapplicable to the year under review. Consequently the CIT(A)'s sustenance of the disallowance was reversed and the deduction was restored. en-us Tue, 26 Aug 2014 00:00:00 +0530 Fri, 05 Sep 2025 12:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251102 ITAT (Del) held partly for the assessee, allowing the contested deduction under s.10A for AY 2009-10. The Tribunal found s.80IA(10) permits scaling down profits if an arrangement with a related person produces extraordinary profits, but the AO failed to demonstrate any such arranged course of transactions with overseas AEs; mere higher profits were insufficient. The proviso to s.80IA(10) (w.e.f. 1.4.2013) was inapplicable to the year under review. Consequently the CIT(A)'s sustenance of the disallowance was reversed and the deduction was restored. Case-Laws Income Tax Tue, 26 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251102