https://www.taxtmi.com/caselaws?id=369921 ITAT Pune held that restriction of deduction under sections 10A and 10AA via section 80IA(10) requires material showing a real arrangement between connected parties to generate more than ordinary profits and abuse the tax concession; close connection or higher margins alone is insufficient. The Tribunal also required fresh examination of the assessee's additional tax holiday claim based on the retrospective amendment and realised export proceeds, directing the Assessing Officer to pass a speaking order after giving opportunity. Transfer pricing adjustment on intra-group administrative and managerial services was likewise remanded for comparison with the advance pricing agreement and related material. en-us Fri, 02 Nov 2018 00:00:00 +0530 Mon, 05 Nov 2018 13:30:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369921 ITAT Pune held that restriction of deduction under sections 10A and 10AA via section 80IA(10) requires material showing a real arrangement between connected parties to generate more than ordinary profits and abuse the tax concession; close connection or higher margins alone is insufficient. The Tribunal also required fresh examination of the assessee's additional tax holiday claim based on the retrospective amendment and realised export proceeds, directing the Assessing Officer to pass a speaking order after giving opportunity. Transfer pricing adjustment on intra-group administrative and managerial services was likewise remanded for comparison with the advance pricing agreement and related material. Case-Laws Income Tax Fri, 02 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369921