Assessee-company, engaged in providing back-office support and data processing services, had SEZ unit eligible for deduction under section 10AA.  For relevant assessment years, assessee had voluntarily offered TP adjustments on account of an APA. Assessing Officer denied Section 10AA deduction on portion of income relatable to TP adjustments made pursuant to APA on ground that assessee had declared TP adjustments in anticipation of adjustments by TPO to avoid rigour of Section 92C(4) and that assessee had not furnished details to show how such TP adjustments arose as eligible profits and only gains derived from exports were to be allowed. On appeal, the Commissioner (Appeals) allowed the appeal and found that the exemption under section 10AA could not be denied on the enhanced income and the proviso to section 92C(4) was not a bar for allowing such a claim. Tribunal affirmed the order of the CIT(A).On appeal the Court held that  where assessee had voluntarily factored in ALP pursuant to APA entered into with CBDT, for computing income as declared in its returns, Assessing Officer could not deny exemption under section 10AA in respect of declared income of assessee insofar as it related to TP adjustments made pursuant to APA. (AY.2015-16,  2016-17)