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    <title>2025 (10) TMI 529 - ITAT MUMBAI</title>
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    <description>ITAT, Mumbai upheld that sale of electricity between the captive power plant and the manufacturing unit qualified as an SDT but the TPO&#039;s finding that related-party transactions were at arm&#039;s length must be respected; AO cannot independently reassess ALP. Challenges to disallowances under s.14A (and its application to book profit u/s 115J) were dismissed following prevailing precedents. Deductions under s.35(2AB) and additional depreciation under s.32(1) were allowed as in prior years; depreciation for earlier foreign exchange loss was granted. First appellate authority rightly admitted and accepted claims that SHIS and fertilizer subsidies are capital in nature.</description>
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    <pubDate>Thu, 25 Sep 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=779733</link>
      <description>ITAT, Mumbai upheld that sale of electricity between the captive power plant and the manufacturing unit qualified as an SDT but the TPO&#039;s finding that related-party transactions were at arm&#039;s length must be respected; AO cannot independently reassess ALP. Challenges to disallowances under s.14A (and its application to book profit u/s 115J) were dismissed following prevailing precedents. Deductions under s.35(2AB) and additional depreciation under s.32(1) were allowed as in prior years; depreciation for earlier foreign exchange loss was granted. First appellate authority rightly admitted and accepted claims that SHIS and fertilizer subsidies are capital in nature.</description>
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