Voluntary TP Adjustment under APA Eligible for 10AA Deduction: Karnataka HC

PCIT Vs EYGBS (India) Pvt Ltd (Karnataka High Court)

Karnataka HC: 10AA Deduction Allowed on APA-Based TP Adjustments – Voluntary ALP Declaration Not Hit by Section 92C(4) Proviso

Facts

M/s EYGBS (India) Pvt. Ltd., engaged in back-office & data processing services, filed returns for AYs 2015-16 & 2016-17 claiming deduction u/s 10AA for its SEZ unit. After entering into an Advance Pricing Agreement (APA) with the CBDT, it voluntarily enhanced its income to reflect arm’s length pricing adjustments—₹11.96 crore (AY 2015-16) & â

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