Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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