Disallowance u/s 10B(7) r.w.s. 80IA(10) with material evidence is unsustainable

ACIT Vs HSBC Software Development (India) Pvt. Ltd (ITAT Pune) ITAT Pune held that AO had not brought any material indicating the existence of an arrangement between the assessee company and its foreign AE, as a result of which more profits than ordinarily have been produced to the assessee company. Hence, provisions of section 10B(7) r.w.s. 80IA have no application. Facts- The assessee is engaged in the business of development and sale of software development services and IT solutions to HSBC group of companies. The return of income for AY 2010-11 was filed on 05.10.2010 declaring total incom...