https://www.taxtmi.com/caselaws?id=774680 ITAT Delhi upheld CIT(A)'s deletion of transfer pricing adjustments for power transfer between eligible and non-eligible units, following SC precedent in Jindal Steel case that accepted SEB rates as market value for Section 80IA purposes. For steam transfer, ITAT maintained cost-based pricing as appropriate, recognizing steam as valuable commercial product. Section 14A disallowance was deleted where assessee had sufficient interest-free funds exceeding exempt investments. Education cess deduction was denied following SC ruling in Sesa Goa case. Various transfer pricing adjustments were modified, including inclusion of additional comparables for hybrid seed transactions and deletion of interest on receivables adjustment. Several issues were remanded to AO for verification, including Section 50C valuation through DVO reference and foreign tax credit claims. en-us Mon, 30 Jun 2025 00:00:00 +0530 Sat, 12 Jul 2025 08:40:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774680 ITAT Delhi upheld CIT(A)'s deletion of transfer pricing adjustments for power transfer between eligible and non-eligible units, following SC precedent in Jindal Steel case that accepted SEB rates as market value for Section 80IA purposes. For steam transfer, ITAT maintained cost-based pricing as appropriate, recognizing steam as valuable commercial product. Section 14A disallowance was deleted where assessee had sufficient interest-free funds exceeding exempt investments. Education cess deduction was denied following SC ruling in Sesa Goa case. Various transfer pricing adjustments were modified, including inclusion of additional comparables for hybrid seed transactions and deletion of interest on receivables adjustment. Several issues were remanded to AO for verification, including Section 50C valuation through DVO reference and foreign tax credit claims. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774680