Sec 10A / 10B: Bar in section 92CA(4) not applies to suo motu TP adjustments

Approva Systems Pvt. Ltd Vs. DCIT (ITAT Pune) Now, coming to the second claim of deduction under section 10B/10A of the Act on TP adjustment of Rs 64,07,399/-. The assessee on its own motion had offered adjustment on account of transfer pricing provision to the extent of Rs 64,07,399/-. The computation of income is placed at page 40 of the Paper Book. The assessee claims that on the aforesaid additional income offered, it is entitled to claim the benefit of deduction under section 10B/10A of the Act. We may point herein itself that in the return of income, the assessee had claimed the said de...