https://www.taxtmi.com/caselaws?id=465275 ITAT Pune upheld the CIT(A)'s order allowing deduction u/s 10A to the assessee's STPI unit and deleting the addition made by the AO. The AO had invoked the "more than ordinary profits" concept, alleging that lower salaries paid to key personnel artificially inflated eligible profits. The Tribunal held that the salaries were pre-decided, static over years, and not arranged to inflate profits; employees could not foresee future profits at the year's start. The AO failed to demonstrate any business arrangement resulting in abnormal profits as contemplated by ss. 10A(9)/80IA(10). Consequently, the Revenue's appeal was dismissed. en-us Mon, 28 Apr 2014 00:00:00 +0530 Sun, 14 Dec 2025 11:30:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465275 ITAT Pune upheld the CIT(A)'s order allowing deduction u/s 10A to the assessee's STPI unit and deleting the addition made by the AO. The AO had invoked the "more than ordinary profits" concept, alleging that lower salaries paid to key personnel artificially inflated eligible profits. The Tribunal held that the salaries were pre-decided, static over years, and not arranged to inflate profits; employees could not foresee future profits at the year's start. The AO failed to demonstrate any business arrangement resulting in abnormal profits as contemplated by ss. 10A(9)/80IA(10). Consequently, the Revenue's appeal was dismissed. Case-Laws Income Tax Mon, 28 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465275