Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers.

Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers. https://www.taxtmi.com/highlights?id=78669 The Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions. en-us Thu, 20 Jun 2024 13:52:38 +0530 Thu, 20 Jun 2024 13:52:38 +0530 TaxTMI RSS Generator Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers. https://www.taxtmi.com/highlights?id=78669 The Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions. Highlights Income Tax Thu, 20 Jun 2024 13:52:38 +0530 https://www.taxtmi.com/highlights?id=78669