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 Electricity Act, 2003 gives the State Electricity Regulatory Commission exclusive tariff jurisdiction, and Regulation 20 requires it to consider incentives or subsidies availed by a generating company when fixing tariff. A Union incentive scheme is not immune from regulatory consideration merely because it is a Parliamentary grant, since the Commission regulates the tariff payable by the distribution licensee and does not intercept the grant itself. Tariff fixation must also serve the statutory objective of promoting renewable energy. On that basis, the Generation Based Incentive was treated as a benefit for renewable generators over and above tariff, not as a deduction from tariff.
The Electricity Act, 2003 gives the State Electricity Regulatory Commission exclusive tariff jurisdiction, and Regulation 20 requires it to consider incentives or subsidies availed by a generating company when fixing tariff. A Union incentive scheme is not immune from regulatory consideration merely because it is a Parliamentary grant, since the Commission regulates the tariff payable by the distribution licensee and does not intercept the grant itself. Tariff fixation must also serve the statutory objective of promoting renewable energy. On that basis, the Generation Based Incentive was treated as a benefit for renewable generators over and above tariff, not as a deduction from tariff.
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