Section 10A benefit allowed on Enhanced Income pursuant to MAP Resolution

Dell International Services India Private Limited v. DCIT (ITAT Bangalore)

Benefit of Section 10A of the Act is Allowed on Enhanced Income Pursuant to Mutual Agreement Procedure (MAP) Resolution

Outcome: In favor of Assessee

Facts:

1. During the relevant year, the assessee has provided ITeS and Software Development Services (SWD) of INR 629,43,81,078 and INR 149,69,17,786 respectively for which a TP A

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