https://www.taxtmi.com/caselaws?id=763586 ITAT Bangalore dismissed the AO's appeal regarding deduction under section 10AA on voluntary ALP adjustment made pursuant to APA. The tribunal held that ALP adjustment by the assessee for Gurgaon SEZ unit increases business profits, making the increased profits eligible for section 10AA deduction given the wide expression "profits of the business of the undertaking/unit." The proviso to section 92C(4) does not bar such claims. The CIT(A)'s order was upheld following coordinate bench precedent and Karnataka HC decision. en-us Thu, 19 Dec 2024 00:00:00 +0530 Sat, 21 Dec 2024 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763586 ITAT Bangalore dismissed the AO's appeal regarding deduction under section 10AA on voluntary ALP adjustment made pursuant to APA. The tribunal held that ALP adjustment by the assessee for Gurgaon SEZ unit increases business profits, making the increased profits eligible for section 10AA deduction given the wide expression "profits of the business of the undertaking/unit." The proviso to section 92C(4) does not bar such claims. The CIT(A)'s order was upheld following coordinate bench precedent and Karnataka HC decision. Case-Laws Income Tax Thu, 19 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763586