https://www.taxtmi.com/caselaws?id=275274 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on both issues. Regarding the deletion of addition under Section 36(1)(iii), it was found that the disallowance did not impact the Assessee's taxable income as it related to exempt income under Section 10B. Concerning the deletion of the upward adjustment of Rs. 10,83,00,000/- in international transactions, it was determined that the arm's length price should be based on the specific transaction, not the entity level, and the Assessee's transaction was deemed at arm's length. The Tribunal concluded that the Revenue's grounds lacked merit, and the appeal was dismissed on 12.05.2017. en-us Fri, 12 May 2017 00:00:00 +0530 Wed, 26 Sep 2018 09:01:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275274 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decisions on both issues. Regarding the deletion of addition under Section 36(1)(iii), it was found that the disallowance did not impact the Assessee's taxable income as it related to exempt income under Section 10B. Concerning the deletion of the upward adjustment of Rs. 10,83,00,000/- in international transactions, it was determined that the arm's length price should be based on the specific transaction, not the entity level, and the Assessee's transaction was deemed at arm's length. The Tribunal concluded that the Revenue's grounds lacked merit, and the appeal was dismissed on 12.05.2017. Case-Laws Income Tax Fri, 12 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275274