Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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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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