Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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