Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
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