Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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The ITAT directed the AO/TPO to base transfer pricing adjustments for electricity supplied from eligible to non-eligible units on the industry-standard transmission loss as determined by the Regulatory Authority, rather than the actual loss claimed by the assessee, which lacked supporting evidence. The transmission loss of 17.49% asserted by the assessee was rejected in the absence of proof, and the ALP was to be recalculated accordingly. Regarding steam transfer pricing, the Tribunal found the TPO's conversion method flawed and upheld the assessee's calculation, ordering the AO/TPO to recompute the cost of steam considering the assessee's submissions. Consequently, the ITAT partly allowed the appeal, mandating recalculation of transfer pricing adjustments for electricity and steam in line with prescribed regulatory norms and corrected methodologies.
The ITAT directed the AO/TPO to base transfer pricing adjustments for electricity supplied from eligible to non-eligible units on the industry-standard transmission loss as determined by the Regulatory Authority, rather than the actual loss claimed by the assessee, which lacked supporting evidence. The transmission loss of 17.49% asserted by the assessee was rejected in the absence of proof, and the ALP was to be recalculated accordingly. Regarding steam transfer pricing, the Tribunal found the TPO's conversion method flawed and upheld the assessee's calculation, ordering the AO/TPO to recompute the cost of steam considering the assessee's submissions. Consequently, the ITAT partly allowed the appeal, mandating recalculation of transfer pricing adjustments for electricity and steam in line with prescribed regulatory norms and corrected methodologies.
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