Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous rulings, held that the market value for computing profits from the CPP should be based on the rate at which the State Electricity Board (SEB) supplied power to consumers. The tribunal directed the deletion of the transfer pricing adjustment and allowed the deduction under Section 80IA based on the transfer price of Rs. 8.48 per unit.
Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous rulings, held that the market value for computing profits from the CPP should be based on the rate at which the State Electricity Board (SEB) supplied power to consumers. The tribunal directed the deletion of the transfer pricing adjustment and allowed the deduction under Section 80IA based on the transfer price of Rs. 8.48 per unit.
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