Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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For determining the arm's length price of inter-unit electricity transfers from a captive power plant, the Tribunal treated the industrial consumer tariff charged by the State Electricity Board as a valid comparable uncontrolled price and the proper measure of market value under the transfer pricing framework. It rejected the Revenue's contention that the distributor tariff was distorted by distribution functions, assets and risks, and declined to use the generator's sale rate as the benchmark. Following Supreme Court and High Court authorities, it upheld deletion of the transfer pricing adjustment on the captive power transfer and applied the same view to the remaining years on identical facts.
For determining the arm's length price of inter-unit electricity transfers from a captive power plant, the Tribunal treated the industrial consumer tariff charged by the State Electricity Board as a valid comparable uncontrolled price and the proper measure of market value under the transfer pricing framework. It rejected the Revenue's contention that the distributor tariff was distorted by distribution functions, assets and risks, and declined to use the generator's sale rate as the benchmark. Following Supreme Court and High Court authorities, it upheld deletion of the transfer pricing adjustment on the captive power transfer and applied the same view to the remaining years on identical facts.
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