Deduction U/s. 10AA cannot be scale down merely because assessee makes extraordinary profit

SJR Commodities & Consultancies (P) Ltd. Vs ITO (ITAT Mumbai) Section 80IA(10) of the Act to find out as to whether the AO was empowered to make adjustments to the eligible profit claimed under s.10A of the Act on the grounds of extraordinary profits. As noticed, it is the case of the AO that assessee has indulged in arrangement whereby the profits of non eligible units have been shifted to eligible unit through the conduit of same set of customers and related parties. The AO has accordingly alleged that assessee has made an ‘arrangement’ whereby it did not make any profit from non SEZ...