https://www.taxtmi.com/caselaws?id=781530 ITAT CHENNAI upheld the CIT(A)'s order deleting a transfer-pricing adjustment to captive power valuation under s.80IA(8), holding market value for self-consumed power is the rate at which the assessee purchases electricity from the distribution company and that TP rules do not override s.80IA(8) absent an international transaction. The Tribunal also confirmed deletion of a s.40(a)(ia) disallowance for commission paid to non-resident agents, finding the services were rendered outside India, not taxable here, and procedural filings under s.195(6) were complied with. Revenue's appeals dismissed. en-us Thu, 30 Oct 2025 00:00:00 +0530 Fri, 14 Nov 2025 18:10:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781530 ITAT CHENNAI upheld the CIT(A)'s order deleting a transfer-pricing adjustment to captive power valuation under s.80IA(8), holding market value for self-consumed power is the rate at which the assessee purchases electricity from the distribution company and that TP rules do not override s.80IA(8) absent an international transaction. The Tribunal also confirmed deletion of a s.40(a)(ia) disallowance for commission paid to non-resident agents, finding the services were rendered outside India, not taxable here, and procedural filings under s.195(6) were complied with. Revenue's appeals dismissed. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781530