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    <title>2018 (7) TMI 2209 - ITAT BANGALORE</title>
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    <description>The Tribunal partly allowed the appeals filed by both the assessee and the revenue. The Transfer Pricing issue was directed back to the Assessing Officer/Transfer Pricing Officer for fresh analysis based on the settlement reached under the Mutual Agreement Procedure for international transactions with the US Associated Enterprise. The decision to tax the amount received on relinquishment of the lease option as Capital Gains was upheld, considering lease options akin to tenancy rights. The deduction under Section 10A for the Pune STPI unit was disallowed due to discrepancies in the invoices and Softex forms, leading to a conclusion that the requirements for the deduction were not met.</description>
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