Appeal allowed: conversion treated as manufacture, entitlement under Notification No.56/2002-CE and CENVAT credits reinstated, including returned and ...
ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
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