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Section 10A benefit allowed on Enhanced Income pursuant to MAP Resolution
Case Law Details
- Case Name
- Dell International Services India Private Limited v. DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2007-08
- Courts
- All ITAT, ITAT Bangalore
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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 Adjustment to INR 154,56,23,611 towards ITeS and INR 22,98,32,484 towards SWD respectively was made by Ld. TPO.
ITeS Segment:
2. As far as TP Adjustment towards ITeS services is concerned, during...
Author Info
