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The ITAT upheld the deletion of transfer pricing adjustments related to power and steam transfers between eligible and non-eligible units under section 80IA, affirming the CIT(A)'s order. It directed the AO to verify additional evidence and claims for revised deductions under section 80IA concerning steam transfers. Disallowances under section 14A read with Rule 8D were deleted, given sufficient interest-free funds, and no addition was allowed in book profits under section 115JB. The AO was directed to re-compute the arm's length price for hybrid seed sales after including specified comparables. Issues of foreign tax credit delay, interest disallowance, and discrepancies in sales reporting were remitted to AO for verification. Double additions and disallowances by CPC were set aside. The AO was further directed to allow deductions under section 80IA as per Form 10CCB and grant foreign tax credit under section 90. Other disputed claims were either dismissed or remanded for fresh adjudication in accordance with law.
The ITAT upheld the deletion of transfer pricing adjustments related to power and steam transfers between eligible and non-eligible units under section 80IA, affirming the CIT(A)'s order. It directed the AO to verify additional evidence and claims for revised deductions under section 80IA concerning steam transfers. Disallowances under section 14A read with Rule 8D were deleted, given sufficient interest-free funds, and no addition was allowed in book profits under section 115JB. The AO was directed to re-compute the arm's length price for hybrid seed sales after including specified comparables. Issues of foreign tax credit delay, interest disallowance, and discrepancies in sales reporting were remitted to AO for verification. Double additions and disallowances by CPC were set aside. The AO was further directed to allow deductions under section 80IA as per Form 10CCB and grant foreign tax credit under section 90. Other disputed claims were either dismissed or remanded for fresh adjudication in accordance with law.
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