INDIAN METALS AND FERRO ALLOYS LTD,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANESWAR

ITA 506/CTK/2024Status: DisposedITAT Cuttack19 August 2025AY 2021-22Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT (KZ), SHRI RAKESH MISHRA (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the DRP's decision did not consider the amendment in the definition of 'market value' and the Hon'ble Delhi High Court's decision in DCM Shriram Ltd. Therefore, the Tribunal set aside the AO's order and directed the DRP to reconsider its decision in light of these factors.

What were the facts?

The assessee, Indian Metals and Ferro Alloys Ltd., filed its return of income for AY 2021-22. The case was selected for scrutiny due to large specified domestic transactions, leading to a reference to the Transfer Pricing Officer (TPO). The TPO made a downward adjustment of Rs. 182,23,39,293/- regarding the transfer of power, which was upheld by the Dispute Resolution Panel (DRP).

What were the issues?

The key issues were whether the TPO and DRP erred in determining the arm's length price (ALP) for the transfer of power, particularly by disregarding the assessee's determined ALP and the applicability of Supreme Court and High Court decisions on market value for Section 80-IA deductions.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA(3),Section 92D,Section 80-IA,Section 234B,Section 234C,Section 270A

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Income Tax Appellate Tribunal, CUTTACK BENCH AT KOLKATA

Before: SHRI DUVVURU RL REDDY(KZ) & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Assessing Officer (hereinafter referred to as Ld. 'AO') passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2021-22 dated 28.10.2024, which has I.T.A. No.: 506/CTK/2024 Assessment Year: 2021-22 Indian Metals and Ferro Alloys Ltd. been passed after considering the directions of the DRP u/s 144C(5) of the Act, da

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