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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...
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The ITAT upheld the AO's transfer pricing adjustments except for the valuation of electricity and steam transfers between eligible and non-eligible units. The Tribunal ruled that electricity transfers should be valued at market rates charged by distribution companies, not at the TPO's adjusted rate, deleting the Rs. 32.68 crore adjustment. Similarly, steam transfers cannot be valued at nil cost as by-products; instead, cost of production valuation was accepted, deleting the Rs. 51.63 crore adjustment. The adhoc 10% disallowance on legal and consultancy fees was set aside and remanded for verification of TDS compliance per DRP directions. The issue of customs duty discrepancies was also remanded for fresh verification. Interest under sections 234B and 234C is mandatory but to be computed on the income determined post-order. Grounds relating to electricity and steam valuation were allowed; others were remanded or partly allowed.
The ITAT upheld the AO's transfer pricing adjustments except for the valuation of electricity and steam transfers between eligible and non-eligible units. The Tribunal ruled that electricity transfers should be valued at market rates charged by distribution companies, not at the TPO's adjusted rate, deleting the Rs. 32.68 crore adjustment. Similarly, steam transfers cannot be valued at nil cost as by-products; instead, cost of production valuation was accepted, deleting the Rs. 51.63 crore adjustment. The adhoc 10% disallowance on legal and consultancy fees was set aside and remanded for verification of TDS compliance per DRP directions. The issue of customs duty discrepancies was also remanded for fresh verification. Interest under sections 234B and 234C is mandatory but to be computed on the income determined post-order. Grounds relating to electricity and steam valuation were allowed; others were remanded or partly allowed.
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