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No Downward Adjustment Under 80IA Because CPP Transfer Valued Using SEB Consumer Tariff
Case Law Details
- Case Name
- Aditya BirlaNuvo Ltd. Vs DCIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Mumbai
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Aditya BirlaNuvo Ltd. Vs DCIT (ITAT Mumbai)
ITAT Mumbai Follows Third Member Majority & Holds SEB Purchase Rate as Valid Internal CUP; 80IA Deduction Allowed Without Downward Adjustment
These cross-appeals concerned only one surviving dispute-Ground No 7 relating to determination of market value / ALP for captive transfer of electricity by the assessee’s Captive Power Plant (CPP) to its Rayon manufacturing unit for computing deduction u/s 80IA. Earlier, the Accountant Member (AM) & Judicial Member (JM) delivered differing views, triggering a reference to the Hon’ble Third Member ...
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