2019 (6) TMI 1734

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..... entities based on MAP concluded with US Tax Authorities ITAT justification in holding that exemption u/s 10A is allowable prior to the setting off, of brought forward losses and unabsorbed depreciation. ITAT justification in holding interest income as business income HELD THAT:- It is an agreed position that all these questions had came up for consideration before this Court in case of this v .....

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..... cting to adopt 16.63% Arm's Length margin for transaction relating to non US entities based on MAP concluded with US Tax Authorities, ignoring that MAP proceedings were country specific and result of same should not have been applied for non-US entities transaction ? (b) Whether on the facts and circumstances of the case and in law, the ITAT was justified in holding that exemption under Section .....

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