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‘Market rate’ for inter divisional notional transfer price cannot be based on rate determined by the Regulator
Case Law Details
- Case Name
- Reliance Infrastructure Limited. Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2006- 07
- Courts
- All ITAT, ITAT Mumbai
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‘Market rate’ for the purpose of inter divisional notional transfer price cannot be based on the rate determined by the Regulator
Facts
• Taxpayer is a company engaged in the business of generation and distribution of electricity.
• Originally the taxpayer was only in the business of distribution of electricity. Subsequently, in the assessment year 1996-97, the taxpayer had put up a plant for generation of electricity at Dahanu.
• The taxpayer had claimed deduction under section 80-IA of the Income Tax Act,1961 (the Act) in respect of income from generation and distribution of electr...
