https://www.taxtmi.com/caselaws?id=773205 The ITAT Mumbai ruled in favor of the assessee, holding that section 80IA(10) provisions cannot be invoked without proving the existence of an arrangement between the eligible unit and its associated enterprise (AE). The TPO made a downward adjustment of Rs. 10.98 crore using transfer pricing analysis, but the tribunal found this invalid as the AO failed to establish any pre-existing arrangement. Following the Bombay HC precedent in Schmetz India case, the tribunal emphasized that existence of arrangement is a condition precedent for triggering section 80IA(10). The appeal was allowed entirely. en-us Mon, 16 Jun 2025 00:00:00 +0530 Fri, 27 Jun 2025 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773205 The ITAT Mumbai ruled in favor of the assessee, holding that section 80IA(10) provisions cannot be invoked without proving the existence of an arrangement between the eligible unit and its associated enterprise (AE). The TPO made a downward adjustment of Rs. 10.98 crore using transfer pricing analysis, but the tribunal found this invalid as the AO failed to establish any pre-existing arrangement. Following the Bombay HC precedent in Schmetz India case, the tribunal emphasized that existence of arrangement is a condition precedent for triggering section 80IA(10). The appeal was allowed entirely. Case-Laws Income Tax Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773205