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Transfer Pricing additions not eligible for Exemption U/s 10A
Case Law Details
- Case Name
- M/s. Wissen Infotech Private Limited Vs Dy. Commissioner of Income Tax (ITAT Hyderabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2010-11
- Courts
- All ITAT, ITAT Hyderabad
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Section 92(1) clearly provides that any income arising from an international transaction is required to be computed having regard to its arm’s length price. There is no provision exempting the computation of total income arising from an international transaction having regard to its ALP‘ in the case of an assessee entitled to deduction u/s 8oIC or any other such relevant provision. Section 92C dealing with computation of ALP clearly provides that the ALP in relation to an international transaction shall be determined by one of the methods given in this provision. ...
