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

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