I just made a new character with Deflect and I noticed that this power is not caped in any way. But on Ultimate powers page 40 is said that Defelct can't be higher than the character maximum defense bonus (including any possible trade-off).
So a character with Defense +10 (or 20), Toughness +8 and Deflect 10 should be PL10, rather than PL9.
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