Bombay HC Dismisses Revenue’s Section 10A Appeal, Rejects Section 80IA(10) Profit Adjustment

PCIT Vs Persistent Systems Pvt. Ltd. (Bombay High Court) The Bombay High Court heard an appeal filed by the Revenue challenging the judgment and order dated 12 July 2017 passed by the Income Tax Appellate Tribunal, Pune Bench in Income Tax Appeal No. 1295/PUN/2015 relating to Assessment Year 2010-11. The Revenue reformulated the substantial question of law as follows: Whether the addition made under Section 10A(7) read with Section 80IA(10) of the Income-tax Act, 1961 could have been deleted when the ordinary profits of the comparable companies furnished in the assessee’s transfer pri...