Section 10A benefit allowed on Enhanced Income pursuant to MAP Resolution

Dell International Services India Private Limited v. DCIT (ITAT Bangalore) Benefit of Section 10A of the Act is Allowed on Enhanced Income Pursuant to Mutual Agreement Procedure (MAP) Resolution Outcome: In favor of Assessee Facts: 1. During the relevant year, the assessee has provided ITeS and Software Development Services (SWD) of INR 629,43,81,078 and INR 149,69,17,786 respectively for which a TP Adjustment to INR 154,56,23,611 towards ITeS and INR 22,98,32,484 towards SWD respectively was made by Ld. TPO. ITeS Segment: 2. As far as TP Adjustment towards ITeS services is concerned, during...