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Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proceedings.
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Protective transfer-pricing adjustment on electricity transferred from captive power units to a manufacturing division is discussed where no deduction for eligible power-unit profits was claimed because of returned losses. The notes state that a protective adjustment under normal provisions was unwarranted and that market value for captive consumption is the distribution company's consumer supply rate. They also address export commission paid to non-resident agents procuring orders outside India: where agents have no permanent establishment in India and render no Indian services, the commission is not chargeable to tax in India and tax withholding does not apply. The discussed deletions of the adjustment and commission disallowance were sustained.
Protective transfer-pricing adjustment on electricity transferred from captive power units to a manufacturing division is discussed where no deduction for eligible power-unit profits was claimed because of returned losses. The notes state that a protective adjustment under normal provisions was unwarranted and that market value for captive consumption is the distribution company's consumer supply rate. They also address export commission paid to non-resident agents procuring orders outside India: where agents have no permanent establishment in India and render no Indian services, the commission is not chargeable to tax in India and tax withholding does not apply. The discussed deletions of the adjustment and commission disallowance were sustained.
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