The Tribunal  held that the assessing officer had computed the excess deduction under section 10A of the Act based on the arm’s length price-based profit of the information technology-enabled services rendered vis-à-vis the assessee’s actual profit from such services. The assessee’s associated enterprise being a U. K. company, was not chargeable to tax in India. In other words, if the assessee had suo motu offered higher income in its hands, which was albeit deductible under section 10A, without conferring any corresponding benefit to its associated enterprise in terms of higher deduction of expenditure, the disallowance of excessive deduction under section 10A would not be justified. (A.Y. 2009-10)