Section 10AA Deduction on Enhanced Income Earned through APA

ACIT Vs EYGBS India Pvt. Ltd. (ITAT Bangalore) The issue under consideration is whether the 1st proviso of section 92C(4) is triggered when the income computation for deduction u/s 10AA is enhanced only in the computation of income and no such entries are made in the books of account? ITAT states that, the ITAT Bangalore in case of IBM India Pvt Ltd has held that deduction under section 10AA of the Act has to be allowed on incremental income arisen pursuant to APA as per modified return filed under section 92CD of the Act as same is not hit by proviso to section 92C(4) of the Act. Accordingly,...