https://www.taxtmi.com/caselaws?id=784479 Inter-unit transfer pricing for deduction under s.80-IB(11A) was central: applying SC guidance, the Tribunal held that where processing units lacked an alternative but to buy chilled milk from third parties, the "market value" could validly include weighted average third-party overheads; treating the arm's length price of overheads as nil was unjustified, so the denial of s.80-IB(11A) on this ground was set aside. Compliance with Rule 18BBB/Form 10CCB was found substantially met on unit-wise accounts, but the AO was directed to verify that audit reports for all eligible units were filed; if verified, the related adverse inference would stand vacated. Disallowance under s.14A was upheld in principle but capped to exempt income. Differential-interest disallowance under s.37 was deleted due to sufficient interest-free funds. s.80-JJAA was remanded for re-quantification after verification. en-us Wed, 26 Nov 2025 00:00:00 +0530 Mon, 05 Jan 2026 12:22:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784479 Inter-unit transfer pricing for deduction under s.80-IB(11A) was central: applying SC guidance, the Tribunal held that where processing units lacked an alternative but to buy chilled milk from third parties, the "market value" could validly include weighted average third-party overheads; treating the arm's length price of overheads as nil was unjustified, so the denial of s.80-IB(11A) on this ground was set aside. Compliance with Rule 18BBB/Form 10CCB was found substantially met on unit-wise accounts, but the AO was directed to verify that audit reports for all eligible units were filed; if verified, the related adverse inference would stand vacated. Disallowance under s.14A was upheld in principle but capped to exempt income. Differential-interest disallowance under s.37 was deleted due to sufficient interest-free funds. s.80-JJAA was remanded for re-quantification after verification. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784479