JOINT COMMISSIONER OF INCOME TAX (OSD), CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. ZF WIND POWER COIMBATORE PRIVATE LIMITED, COIMBATORE

ITA 245/CHNY/2025Status: DisposedITAT Chennai01 August 202519 pages
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What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s direction to treat scrap sales as operating income, aligning with previous tribunal decisions. Regarding interest on debentures, the Tribunal noted the CIT(A)'s direction to verify the currency denomination and adopt SBI PLR if denominated in INR.

What were the facts?

The assessee, engaged in manufacturing and assembly of gearboxes for wind turbines, had its international transactions referred to the Transfer Pricing Officer (TPO). The TPO made adjustments regarding the sale of scrap and interest on convertible debentures.

What were the issues?

Whether scrap sales should be treated as operating income for margin computation and the appropriate method for determining the arm's length price of interest on convertible debentures.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 250

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Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, D BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI S.R. RAGHUNATHA

Heard together (2 matters)

C.O No.21/CHNY/2025
I.T.A. No.245/CHNY/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER GEORGE GEORGE K, VICE PRESIDENT:

These appeals filed by the Revenue are directed against two orders of the Commissioner of Income Tax (Appeals), Chennai-16 both dated 28.11.2024 passed u/s.250 of the Income Tax Act (her

The order continues below.

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