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    <title>2017 (12) TMI 1528 - ITAT PUNE</title>
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    <description>The Tribunal reversed the addition of Rs. 34,19,130/- made by the Assessing Officer under section 10B(7) of the Income Tax Act, 1961, as the AO failed to provide sufficient justification for invoking the provision. The Tribunal also rejected the argument that there was an &#039;arrangement&#039; with Associated Enterprises to inflate profits and disagreed with using Arm&#039;s Length Price (ALP) to determine extraordinary profits. Consequently, the interest computation under section 234B was dismissed as the primary adjustments under section 10B(7) were not upheld. The appeal of the assessee was partly allowed.</description>
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    <pubDate>Fri, 15 Dec 2017 00:00:00 +0530</pubDate>
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      <title>2017 (12) TMI 1528 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=353259</link>
      <description>The Tribunal reversed the addition of Rs. 34,19,130/- made by the Assessing Officer under section 10B(7) of the Income Tax Act, 1961, as the AO failed to provide sufficient justification for invoking the provision. The Tribunal also rejected the argument that there was an &#039;arrangement&#039; with Associated Enterprises to inflate profits and disagreed with using Arm&#039;s Length Price (ALP) to determine extraordinary profits. Consequently, the interest computation under section 234B was dismissed as the primary adjustments under section 10B(7) were not upheld. The appeal of the assessee was partly allowed.</description>
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      <pubDate>Fri, 15 Dec 2017 00:00:00 +0530</pubDate>
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