Tribunal  held  that even if the expenditure was disallowed, it would increase the profits of the business eligible for deduction under section 10A/10AA of the Act and consequently the deduction should be allowed on such enhanced profits. This position had been confirmed by the Central Board of Direct Taxes in its Circular No. 37 of 2016, dated November 2, 2016 ([2016] 388 ITR (St.) (62). Relied on  CIT v. Gem Plus Jewellery India Ltd. (2011) 330 ITR  175 (Bom),(HC) ITO  v. Keval Construction (2013) 354 ITR 13 (Guj.)(HC) and CIT v. M. Pact Technology Services Pvt.  Ltd. (I.T.A. No. 228 of 2013, dated July 11, 2018) (Karn.)(HC) Tribunal held that  since there was no tax liability ultimately there was no necessity for adjudicating the validity of initiation of the reassessment proceedings. (AY. 2009-10)