https://www.taxtmi.com/caselaws?id=466191 CUP benchmarking for captive power transfers must reflect the actual price structure used for comparison, so wheeling charges cannot be deducted from the benchmark merely because the consumer separately bears them. Retention money payable, forward contract premium, warranty provision and promotion spend through Cricket Pace Foundation were treated as allowable where they arose on mercantile or business-expediency principles. The incentive deduction for new employment was construed liberally, allowing continuity of service into the succeeding year, and weighted deduction for in-house R&D could not be curtailed solely by a lower DSIR Form 3CL figure for the relevant period. Disallowance under section 14A was capped at exempt income and not applied mechanically to book profits under section 115JB; MAT credit was to be recomputed accordingly. en-us Fri, 28 Feb 2025 00:00:00 +0530 Wed, 28 Jan 2026 19:21:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466191 CUP benchmarking for captive power transfers must reflect the actual price structure used for comparison, so wheeling charges cannot be deducted from the benchmark merely because the consumer separately bears them. Retention money payable, forward contract premium, warranty provision and promotion spend through Cricket Pace Foundation were treated as allowable where they arose on mercantile or business-expediency principles. The incentive deduction for new employment was construed liberally, allowing continuity of service into the succeeding year, and weighted deduction for in-house R&D could not be curtailed solely by a lower DSIR Form 3CL figure for the relevant period. Disallowance under section 14A was capped at exempt income and not applied mechanically to book profits under section 115JB; MAT credit was to be recomputed accordingly. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466191