The Appellate Tribunal considered Transfer Pricing adjustment ...

Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers.

June 20, 2024

Case Laws Income Tax AT

The Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions.

View Source

← Previous Next →

The Appellate Tribunal considered Transfer Pricing adjustment ...

Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers.

June 20, 2024

Case Laws Income Tax AT

You may also like:

The Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

CESTAT determined that while rejection of declared transaction value of imported thoroughbred horses under Rule 10A of Customs Valuation Rules, 1988 was justified due to...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

The assessee, a domestic company, contested the tax rate applied by the authorities for the assessment year 2018-19. The Finance Act, 2017 introduced a concessional tax...

Method of valuation - Revenue neutrality - Extended period of limitation - goods transferred to another unit for captive consumption - to be valued in accordance with...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

The Appellate Tribunal dismissed the Section 7 application filed by the Appellant, ruling that the share application money deposited by the Appellant with the Corporate...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

Undervaluation of goods - FOS and Sucralose when cleared to related parties and M/s Surya Herbals by not following CAS-4 valuation method as provided u/r 8 of Central...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

The CESTAT ruled that the appellant's excisable goods clearance to an inter-connected undertaking should be valued under Rule 10, not Rules 8 & 9 of the Central...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

CENVAT Credit - restrictions in using the cenvat credit for payment of duty for the clearances - Pursuant to quashing of Rule 8(3A) by the Hon’ble Gujarat High Court,...

Quick Updates: