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Assistant Commissioner Of Income Tax, ... vs Loyal Textile Mills Ltd, Kovilpatti on 4 March, 2026
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The Pr. Commissioner Of Income Tax ... vs Jindal Steel And Power Ltd. Through Its ... on 4 October, 2021
The coordinate Bench of the Chennai Tribunal in Eveready Spinning Mills Ltd.
has followed the above decision and held that the transfer pricing provisions do
not override the computation mechanism of section 80IA(8) in the absence of
any international transaction. Case relied upon by the revenue is not binding on
Chennai Bench. The CIT(A) has rightly followed the binding precedent of the
Hon'ble Supreme Court and the jurisdictional Tribunal. The mere insertion of
Explanation to section 80IA(8) by the Finance Act, 2012 does not alter the
settled position insofar as captive generation of power for self-consumption is
concerned, where there is no real income element involved and the pricing is
internal. The Revenue has not demonstrated any factual or legal error in the
CIT(A)'s conclusion. Respectfully following the binding precedents, we uphold
the CIT(A)'s order deleting the adjustment of Rs.4.26 crores."
Section 40 in Finance Act, 2012 [Entire Act]
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