https://www.taxtmi.com/caselaws?id=414479 ITAT DELHI - AT allowed most of the assessee's appeals. It held internal CUP valid only where the assessee both sold to and bought from the SEB (UP), but not in Kota where the assessee only purchased power, so SEB purchase price (external CUP) rather than IEX rates must be used; the TP adjustment was deleted. The tribunal reversed the determination of steam's ALP at nil, directing deletion of the Rs.1,035,745,275 addition and acceptance of cost. Section 14A disallowance was limited to the assessee's offered amount of Rs.6,399,219. The s.50C matter was remitted to the AO to refer to the DVO. Additions under s.115JB were deleted and education cess under s.37(1) was allowed. en-us Thu, 28 Oct 2021 00:00:00 +0530 Tue, 16 Sep 2025 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414479 ITAT DELHI - AT allowed most of the assessee's appeals. It held internal CUP valid only where the assessee both sold to and bought from the SEB (UP), but not in Kota where the assessee only purchased power, so SEB purchase price (external CUP) rather than IEX rates must be used; the TP adjustment was deleted. The tribunal reversed the determination of steam's ALP at nil, directing deletion of the Rs.1,035,745,275 addition and acceptance of cost. Section 14A disallowance was limited to the assessee's offered amount of Rs.6,399,219. The s.50C matter was remitted to the AO to refer to the DVO. Additions under s.115JB were deleted and education cess under s.37(1) was allowed. Case-Laws Income Tax Thu, 28 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414479