ITAT Rules Market Rate Valuation for Electricity, Steam Transfers; Sets Aside Adhoc Legal Fee Disallowance

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....The ITAT upheld the AO's transfer pricing adjustments except for the valuation of electricity and steam transfers between eligible and non-eligible units. The Tribunal ruled that electricity transfers should be valued at market rates charged by distribution companies, not at the TPO's adjusted rate, deleting the Rs. 32.68 crore adjustment. Similarly, steam transfers cannot be valued at nil cost as by-products; instead, cost of production valuation was accepted, deleting the Rs. 51.63 crore adjustment. The adhoc 10% disallowance on legal and consultancy fees was set aside and remanded for verification of TDS compliance per DRP directions. The issue of customs duty discrepancies was also remanded for fresh verification. Interest under section.........