The Assessee is engaged in providing back office support services, in the nature of ‘Information Technology Enabled Services’ (ITES). It adopted TNMM to benchmark its international transaction. It made a voluntary TP adjustment to its financial results and claimed deduction under Section 10AA of the Act against it. The TPO proposed an adjustment by making certain changes in the comparable companies. The DRP directed the AO/TPO to exclude certain comparable companies on the basis that it considered the Assessee company as low end service provider whereas the comparable companies viz. M/s E-Clerx Services Ltd. & M/s Acropetal Technologies Limited were providing high-end services. The Tribunal upheld this direction of the DRP. In respect of disallowance of section 10AA claim on voluntary adjustment, the AO had allowed the said deduction on the voluntary TP adjustment, however, the DRP directed to disallow the claim as- (i)The Assessee has not furnished any details as to how the above said amount was worked out;(ii) Section 10AA mandates the export consideration should be brought into India; (iii) The unit for which deduction has been claimed has actually incurred losses. The Tribunal noted that the first proviso to Section 92C(4) is applicable only to situations where adjustment to the ALP is made by the AO/TPO / DRP. It also appreciated that the Assessee computed the adjustment in a scientific manner by comparing its margins with that of comparable companies selected by the Assessee. The Tribunal observed that artificial income cannot be part of export turnover and hence there could not be any condition for getting such foreign exchange to India. It held that the Assessee was entitled to deduction under Section 10AA of the Act on voluntary transfer pricing adjustment.  Apoorva Systems (P) Ltd (2018)(92 taxmann.com 82); I-Gate Global Solutions Ltd. (2007)(112 TTJ 1002) upheld by Hon’ble Karnataka High Court in ITA 453/ 2008 relied. (ITA No. 218 (Bang) 2015 & 199 (Bang) 2015 Dt. 20.05.2020) (AY 2010-11)