Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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