denying
deduction claimed by the Appellant under section 10AA of the Act;
6.1. On the facts and circumstances of the case ... erred in disregarding the fact that the
disallowance under section 10AA of the Act in the year of
formation has been deleted and thus
Adjustments
4. Ground No.4 - Addition on account of deduction under
section 10AA of the Act amounting to INR 6,88,32,004.
4.1 That ... erred in adjudicating the issue of
deduction under section 10AA of the Act basis the directions
passed for AY 2016-17 without appreciating the fact
have erred, on law and facts, by
making adjustments under section 10AA(9) read with section 80IA(10) of the
Act to the returned income ... eligible profits for the
purpose of computation of deduction under section 10A (erstwhile section
10AA of the Act) of the Act.
6. The learned
Objections before DRP - Pgs.
profits while computing 514-515
deduction under
section 10AA of the Act.
Income from sale of SEIS
scrips form part ... computation of deduction
DRP Directions: Start at under Section 10AA of the Act.
Pg.393, para 3.4
Issue remanded to TPO at
para
assessment, the claim was already made in ITR under Section 10B instead of Section
10AA , this matter is covered by the decision ... return of income the assessee has claimed deduction u/s.
10B instead of section 10AA of the Act which was a typographical
mistake
Disallowance of deduction under section 10AA of the Act -
Rs.3,27,98,725/-
3. Proceeding further, he submitted, the transfer pricing
adjustment in relation ... addition has to be deleted. Insofar as
disallowance of deduction under section 10AA is concerned,
learned counsel submitted, the Assessing Officer has reduced an
amount
Section 40A of the Act empowers the Assessing Officer to disallow
unreasonable expenditure incurred between related parties. Further,
under Chapter VI-A and section 10AA ... same entity for the
purposes of section 40A, Chapter VI-A and section 10AA. The
concerns of administrative and compliance burden are addressed by
restricting
section (1) or sub- section (3) or sub-section
(4A) or sub-section (4B) or sub-section (4C) or sub-
section (4D) [or sub-section ... 2021 10
section 139 or clause (i) of sub-section (1) of section
142 1 [or section 148 ] or section 153A [***] relating to the
assessment
adjustments under section 143(1)(a) of the Act are permissible under
section 143(1) of the Act. The relevant extract of section ... return has been made under section 139 , or in
response to a notice under sub-section (1) of section 142 , such return
shall be processed
return has been made under section 139 , or
in response to a notice under sub-section (1) of section 142 ,
such return shall be processed ... total income in the
return;
(v) disallowance of deduction claimed under [section
10AA or under any of the provisions of Chapter
VI-A under