TP: No deduction u/s 10A on enhanced value after ALP adjustment

Brief of the Case ITAT Delhi held in the case of Headstrong Services India Pvt. Ltd. vs. DCIT that both the submission of the assesses is unacceptable. Regarding first submission for not carrying out any transfer pricing adjustment in view of the benefit enjoyed by it u/s 10A is concerned, we find that no exception has carved out by the statute for non-determination of the ALP of an international transaction of an assesses who is eligible for the benefit of deduction section 10A/10B or any other section. Section 92(1) clearly provides that any income arising from an international transaction i...