Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
The ITAT upheld deletion of transfer pricing adjustments on captive power supplied to eligible manufacturing units for section 80-IA purposes, applying the Supreme Court principle that the relevant market value is the rate charged by the State Electricity Board or distribution company to industrial consumers, not the regulated or contracted surplus-power rate. It accepted the annual landed cost paid by the manufacturing units as the proper benchmark and rejected the Revenue's challenge. The Tribunal also sustained allocation of common head office expenses on the fixed-asset ratio, holding that the Revenue had followed the same method in earlier years and no change in facts or law justified a profitability-based allocation. All four Revenue appeals were dismissed.
The ITAT upheld deletion of transfer pricing adjustments on captive power supplied to eligible manufacturing units for section 80-IA purposes, applying the Supreme Court principle that the relevant market value is the rate charged by the State Electricity Board or distribution company to industrial consumers, not the regulated or contracted surplus-power rate. It accepted the annual landed cost paid by the manufacturing units as the proper benchmark and rejected the Revenue's challenge. The Tribunal also sustained allocation of common head office expenses on the fixed-asset ratio, holding that the Revenue had followed the same method in earlier years and no change in facts or law justified a profitability-based allocation. All four Revenue appeals were dismissed.
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