Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT ruled in favor of the appellant regarding transfer pricing of electricity from its captive power plants to its cement unit. The Tribunal rejected the TPO's benchmarking based on supplies by various power companies, finding that electricity pricing is a regulated activity and therefore not an "uncontrolled condition" suitable for CUP method comparison. Following M/s. Jindal Steel and Power Ltd. (SC, 2023), the ITAT held that the appropriate benchmark was the rate charged by the State Electricity Board (AVVNL) to industrial consumers. The Tribunal concluded that the appellant's transfer price of Rs. 7.40 per unit represented ALP, and directed the deletion of adjustments proposed by the TPO and confirmed by the DRP.
The ITAT ruled in favor of the appellant regarding transfer pricing of electricity from its captive power plants to its cement unit. The Tribunal rejected the TPO's benchmarking based on supplies by various power companies, finding that electricity pricing is a regulated activity and therefore not an "uncontrolled condition" suitable for CUP method comparison. Following M/s. Jindal Steel and Power Ltd. (SC, 2023), the ITAT held that the appropriate benchmark was the rate charged by the State Electricity Board (AVVNL) to industrial consumers. The Tribunal concluded that the appellant's transfer price of Rs. 7.40 per unit represented ALP, and directed the deletion of adjustments proposed by the TPO and confirmed by the DRP.
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