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    <title>2025 (8) TMI 828 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that the order giving effect passed by the TPO pursuant to DRP directions is a procedural document and not independently appealable. The AO/TPO failed to conform to DRP directions regarding deduction u/s 80IA on steam transfer, rendering the assessment void ab initio; the claim of deduction was allowed as the DRP&#039;s directive to treat it as nil was set aside. Additions on sale of electricity using CUP method were deleted as enhancements by AO/TPO and DRP were unjustified. Deduction u/s 35(2AB) was denied due to absence of Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues of double depreciation disallowance, processing fees amortization, and computational errors were remitted to AO for verification and relief if found tenable. Grounds related to these matters were accordingly allowed or dismissed in part.</description>
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    <pubDate>Fri, 25 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 828 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=776640</link>
      <description>ITAT Mumbai held that the order giving effect passed by the TPO pursuant to DRP directions is a procedural document and not independently appealable. The AO/TPO failed to conform to DRP directions regarding deduction u/s 80IA on steam transfer, rendering the assessment void ab initio; the claim of deduction was allowed as the DRP&#039;s directive to treat it as nil was set aside. Additions on sale of electricity using CUP method were deleted as enhancements by AO/TPO and DRP were unjustified. Deduction u/s 35(2AB) was denied due to absence of Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues of double depreciation disallowance, processing fees amortization, and computational errors were remitted to AO for verification and relief if found tenable. Grounds related to these matters were accordingly allowed or dismissed in part.</description>
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      <pubDate>Fri, 25 Jul 2025 00:00:00 +0530</pubDate>
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