Eygbs (India) LLP v. Dy.CIT (2020) 84 ITR 48 (SN) (Bang.)(Trib.)

S. 10AA : Special economic zones-Transfer pricing adjustment-Deduction allowable. [S. 92C]

The assessee, a subsidiary of a Netherlands based company, was engaged in the business of providing back office support services, in the nature of information technology enabled services to its associated enterprises. The assessee was remunerated at “cost plus” basis for the services provided to its associated enterprises. For the assessment year 2012-13, the assessee had made a transfer pricing adjustment voluntarily and added it to the total income. The assessee also claimed deduction under section 10AA of the Income-tax Act, 1961 on the profits of business arrived at after inclusion of transfer pricing adjustment.  Tribunal held that deduction is available in respect of transfer pricing adjustment made by the assessee. (AY.2011-12)