Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
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