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The ITAT affirms the CIT(A)'s deletions and dismisses the Revenue's appeals. The Tribunal holds that for deduction computation under s.80IA(8) the market value of captive power consumed is the rate at which the assessee purchases electricity from the distribution company, and transfer pricing provisions do not override s.80IA(8) where no international transaction or real income element exists; the Explanation inserted in 2012 does not alter this position. Separately, the Tribunal upholds deletion of a s.40(a)(ia) disallowance for commissions paid to non-resident agents, concluding the services were rendered outside India, no income accrued in India, s.195 was not attracted and procedural compliance under s.195(6) was met.
The ITAT affirms the CIT(A)'s deletions and dismisses the Revenue's appeals. The Tribunal holds that for deduction computation under s.80IA(8) the market value of captive power consumed is the rate at which the assessee purchases electricity from the distribution company, and transfer pricing provisions do not override s.80IA(8) where no international transaction or real income element exists; the Explanation inserted in 2012 does not alter this position. Separately, the Tribunal upholds deletion of a s.40(a)(ia) disallowance for commissions paid to non-resident agents, concluding the services were rendered outside India, no income accrued in India, s.195 was not attracted and procedural compliance under s.195(6) was met.
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