Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT held that the transfer price of steam-generated electricity from an eligible unit to a non-eligible unit must be determined based on the market value charged by State Electricity Boards or distribution companies to end consumers, in accordance with the Electricity Act framework. Since the appellant's boilers generated steam solely for captive consumption and no external sale of steam occurred, the pricing cannot be arbitrary but must reflect regulated electricity tariffs. Consequently, the AO was directed to recompute eligible profits under Section 80IA(8) by applying the electricity rates charged by the respective distribution companies in the relevant states. The appeal was partly allowed to this extent, ensuring the transfer pricing adjustment aligns with statutory electricity pricing norms rather than internal transfer valuations.
The ITAT held that the transfer price of steam-generated electricity from an eligible unit to a non-eligible unit must be determined based on the market value charged by State Electricity Boards or distribution companies to end consumers, in accordance with the Electricity Act framework. Since the appellant's boilers generated steam solely for captive consumption and no external sale of steam occurred, the pricing cannot be arbitrary but must reflect regulated electricity tariffs. Consequently, the AO was directed to recompute eligible profits under Section 80IA(8) by applying the electricity rates charged by the respective distribution companies in the relevant states. The appeal was partly allowed to this extent, ensuring the transfer pricing adjustment aligns with statutory electricity pricing norms rather than internal transfer valuations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
