https://www.taxtmi.com/caselaws?id=313807 ITAT PUNE held that AO lacked jurisdiction to curtail section 10AA deduction for SEZ unit profits by invoking section 80IA(10) merely due to higher margins. Revenue failed to establish any arrangement between parties for earning extraordinary profits. The assessee provided high-end knowledge-based software development services to unrelated concerns after closing its STPI unit. Without proving artificial arrangements, higher margins alone cannot justify reducing deduction. However, common expenses totaling Rs. 17,53,709 were reallocated from STPI to SEZ unit, reducing eligible profits to Rs. 7.31 crores for section 10AA deduction calculation. en-us Mon, 11 Feb 2019 00:00:00 +0530 Fri, 03 May 2024 15:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313807 ITAT PUNE held that AO lacked jurisdiction to curtail section 10AA deduction for SEZ unit profits by invoking section 80IA(10) merely due to higher margins. Revenue failed to establish any arrangement between parties for earning extraordinary profits. The assessee provided high-end knowledge-based software development services to unrelated concerns after closing its STPI unit. Without proving artificial arrangements, higher margins alone cannot justify reducing deduction. However, common expenses totaling Rs. 17,53,709 were reallocated from STPI to SEZ unit, reducing eligible profits to Rs. 7.31 crores for section 10AA deduction calculation. Case-Laws Income Tax Mon, 11 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313807