The Appellate Tribunal considered Transfer Pricing adjustment ...

Issues on transfer pricing adjustment u/s 92 resolved in favor of Appellant. Correct comparison & method accepted. Additional ground admitted for deduction u/s 80-IA for further consideration.

Case Laws Income Tax

June 20, 2024

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.

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The Appellate Tribunal considered Transfer Pricing adjustment ...

Issues on transfer pricing adjustment u/s 92 resolved in favor of Appellant. Correct comparison & method accepted. Additional ground admitted for deduction u/s 80-IA for further consideration.

Case Laws Income Tax

June 20, 2024

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