https://www.taxtmi.com/caselaws?id=387898 Foreign exchange gain arising from SEZ business receipts was treated as trading income linked to revenue account, so it remained eligible for exemption under section 10AA. The Assessing Officer's proportionate salary attribution to SEZ units was unsustainable because the salary allocation was already reflected in the audited books and the adjustment exceeded the proper factual and statutory basis, with no applicable transfer pricing threshold on the record. For book profit under section 115JB, only the additions and reductions expressly provided in the statutory Explanation can be made, so the impugned adjustments were impermissible. en-us Thu, 31 Oct 2019 00:00:00 +0530 Mon, 04 Nov 2019 07:11:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387898 Foreign exchange gain arising from SEZ business receipts was treated as trading income linked to revenue account, so it remained eligible for exemption under section 10AA. The Assessing Officer's proportionate salary attribution to SEZ units was unsustainable because the salary allocation was already reflected in the audited books and the adjustment exceeded the proper factual and statutory basis, with no applicable transfer pricing threshold on the record. For book profit under section 115JB, only the additions and reductions expressly provided in the statutory Explanation can be made, so the impugned adjustments were impermissible. Case-Laws Income Tax Thu, 31 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387898