Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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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