https://www.taxtmi.com/caselaws?id=795757 No adjustment to eligible-unit profits arises where no deduction under section 80-IA is claimed because the taxpayer has returned losses; a protective transfer-pricing adjustment for captive power transfers therefore has no effect under normal provisions. For determining market value independently, the relevant benchmark is the tariff charged by a distribution company to industrial consumers. Export commission paid to non-resident agents is not subject to tax deduction at source where agents procure orders outside India, render no services in India, and have no Indian permanent establishment, because the commission is not chargeable to tax in India. en-us Tue, 21 Jul 2026 00:00:00 +0530 Mon, 27 Jul 2026 08:27:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795757 No adjustment to eligible-unit profits arises where no deduction under section 80-IA is claimed because the taxpayer has returned losses; a protective transfer-pricing adjustment for captive power transfers therefore has no effect under normal provisions. For determining market value independently, the relevant benchmark is the tariff charged by a distribution company to industrial consumers. Export commission paid to non-resident agents is not subject to tax deduction at source where agents procure orders outside India, render no services in India, and have no Indian permanent establishment, because the commission is not chargeable to tax in India. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795757