Tag Archives: Persistent Systems (P.) Ltd.

High Court Rejects Section 10A/80IA(10) Additions Absent Finding of Extraordinary Counterparty Profits Issue Whether additions under Section 10A(7) read with Section 80IA(10) can be sustained solely based on a transfer pricing margin comparison without establishing that transactions with counterparties yielded more than ordinary profits. Facts The assessee claimed deduction under Section 10A for the Assessment… Read More »

Section 10A Addition Is Invalid Without Material Proving Assessee’s Dealings Yielded More Than Ordinary Profits Issue Whether the Assessing Officer was justified in making additions under Section 10A(7) read with Section 80IA(10) merely because the assessee’s net profit margin (27.86%) was higher than the average profit margin of comparables (9.35%), without establishing that the dealings… Read More »