Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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