Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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