Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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The ITAT allowed the assessee's appeal on the issue of disallowance of deduction u/s 80-IA. It held that the arm's length price for transfer of power from the captive power unit to the steel manufacturing unit should be the rate at which the State Electricity Board supplies power to industrial consumers, and not the rate at which it purchases power from suppliers. This is in line with the jurisdictional High Court's judgment in CIT v Godavari Power & Ispat Ltd and the Supreme Court's judgment in CIT v Jindal Steel and Power Ltd. Regarding the disallowance of deduction u/s 80G for donations, the ITAT restored the issue to the Assessing Officer for fresh adjudication after verifying whether the donations satisfied the conditions of section 80G. It also restored the connected issue of double disallowance of deduction u/s 80G to the Assessing Officer for re-adjudication.
The ITAT allowed the assessee's appeal on the issue of disallowance of deduction u/s 80-IA. It held that the arm's length price for transfer of power from the captive power unit to the steel manufacturing unit should be the rate at which the State Electricity Board supplies power to industrial consumers, and not the rate at which it purchases power from suppliers. This is in line with the jurisdictional High Court's judgment in CIT v Godavari Power & Ispat Ltd and the Supreme Court's judgment in CIT v Jindal Steel and Power Ltd. Regarding the disallowance of deduction u/s 80G for donations, the ITAT restored the issue to the Assessing Officer for fresh adjudication after verifying whether the donations satisfied the conditions of section 80G. It also restored the connected issue of double disallowance of deduction u/s 80G to the Assessing Officer for re-adjudication.
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