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    <title>2024 (2) TMI 276 - ITAT MUMBAI</title>
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    <description>Disallowance of alleged inflated coal purchase expenses was deleted where the Assessing Officer&#039;s case rested on DRI allegations of overvaluation through intermediary firms, but the related customs proceedings had already been dropped or set aside and the appellate orders had attained finality. The Tribunal also noted that the assessee&#039;s electricity business operated under a regulated cost-plus tariff framework, so fuel cost was part of tariff ination and the corresponding receipts had already been offered to tax. On that footing, the material relied on by the Revenue was insufficient to sustain the addition, and the first appellate relief was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=449125</link>
      <description>Disallowance of alleged inflated coal purchase expenses was deleted where the Assessing Officer&#039;s case rested on DRI allegations of overvaluation through intermediary firms, but the related customs proceedings had already been dropped or set aside and the appellate orders had attained finality. The Tribunal also noted that the assessee&#039;s electricity business operated under a regulated cost-plus tariff framework, so fuel cost was part of tariff ination and the corresponding receipts had already been offered to tax. On that footing, the material relied on by the Revenue was insufficient to sustain the addition, and the first appellate relief was upheld.</description>
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