https://www.taxtmi.com/caselaws?id=471911 Transfer-pricing adjustments for accounting and BPO exports fail where comparables lack functional similarity, reliable financial data, or acceptable related-party transaction levels, and the resulting margins are lower than or within the statutory tolerance range of the taxpayer's margin. For MAT purposes, the section 10A reduction from book profit is determined from the eligible unit's profit under book-profit principles, rather than the deduction under normal computation provisions; corresponding additions are deleted. A business-expenditure disallowance under section 40(a)(ia) increases the eligible undertaking's profit, so the section 10A deduction extends to that enhanced profit. en-us Tue, 25 Jul 2023 00:00:00 +0530 Wed, 23 Sep 2026 12:34:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471911 Transfer-pricing adjustments for accounting and BPO exports fail where comparables lack functional similarity, reliable financial data, or acceptable related-party transaction levels, and the resulting margins are lower than or within the statutory tolerance range of the taxpayer's margin. For MAT purposes, the section 10A reduction from book profit is determined from the eligible unit's profit under book-profit principles, rather than the deduction under normal computation provisions; corresponding additions are deleted. A business-expenditure disallowance under section 40(a)(ia) increases the eligible undertaking's profit, so the section 10A deduction extends to that enhanced profit. Case-Laws Income Tax Tue, 25 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471911