Honeywell Automation India Ltd. v. Dy. CIT (2022)95 ITR 51 (Pune) (Trib)

S. 10A : Free trade zone-Transaction between related parties-Restriction of deduction is held to be not justified. [S. 80IA(10)]

Held, that the Assessing Officer had not proved that any arrangement existed between the parties which resulted in higher profits. Consequently, the reworking of the profits by the Assessing Officer invoking section 10A read with section 80IA(10) was not justified. The action of the Assessing Officer in restricting the deduction under section 10A was set aside. Therefore, the order of the Commissioner (Appeals) was not justified.(AY.2005-06)