USHA MARTIN LTD ,KOLKATA vs. ACIT CIR-3, RANCHI

ITA 272/RAN/2017Status: DisposedITAT Ranchi29 July 202612 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the appeal partly, directing adjustments for corporate guarantee at 0.5%, recomputing interest at 9%, deleting ad-hoc disallowance for foreign travel, adopting State Electricity Board rates for Section 80IA deduction, and treating carbon credit receipts as capital receipts.

What were the facts?

The assessee appealed against the CIT(A)'s order for AY 2008-09. Several grounds were raised concerning international transactions, corporate guarantee, interest rates, foreign travel expenses, electricity tariff for Section 80IA deduction, and the nature of carbon credit receipts.

What were the issues?

The key issues involved the determination of arm's length price for corporate guarantees and interest on loans, deductibility of foreign travel expenses, the correct tariff for Section 80IA deduction, and the tax treatment of carbon credit receipts.

Which sections of the Income-tax Act were involved?

Section 80IA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY

For Appellant: Shri Vishal Jain, AR
For Respondent: Shri H. Robindro Singh, ld CIT DR
Hearing: 29/07/2026Pronounced: 29/07/2026

Per Bench This is an appeal filed by the assessee against the order of the ld CIT(A), Ranchi dated 4.8.2017 in Appeal No.468/Ran/Oth/11-12 for the assessment year 2008-09

2.

Shri H.Robindro Singh, Ld CIT DR appeared for the revenue and Shri Vishal Jain, ld AR appeared for the assessee.

3.

At the time of hearing, ld AR of the assessee has filed a synopsis in regard to grounds, which reads as follows:

P a g e 1 | 12 Assessment Year: 2008-09

P a g e 2 | 12 Assessment Year: 2008-09

P a g e 3 | 12 Assessment Year: 2008-09

P a g e 4 | 12 Assessment Year: 2008-09

4.

At the time of hearing, ld AR has submitted that he does not wish to press Ground No.3, 4.1,4.2,4.3,5.1 and 5. 2. Ld AR has en

The order continues below.

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