SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

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ITA 702/ASR/2024Status: DisposedITAT Amritsar16 December 2025AY 2021-2232 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's method for determining the ALP of electricity was reasonable and acceptable, as it was less than the prescribed tariff for biomass-based projects. The Tribunal also found that the sale of steam was eligible for deduction under Section 80IA and that there was an error in the calculation of losses, leading to a double deduction.

What were the facts?

The assessee, engaged in paper manufacturing, generated electricity and steam in a captive unit and transferred it to its non-specified paper manufacturing unit. The assessee claimed exemption under Section 80IA(4)(iv) for the power and steam generated. The TPO proposed adjustments to the arm's length price (ALP) of these transactions.

What were the issues?

The primary issues were the determination of the arm's length price for electricity and steam transferred between units and the allowability of CSR expenses under Section 80G.

Which sections of the Income-tax Act were involved?

Section 80IA,Section 92CA,Section 80G

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Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: DR. M. L. MEENA & SH. UDAYAN DASGUPTA

For Appellant: Adv. &
Hearing: 22.09.2025Pronounced: 16.12.2025

per se. Accordingly, AO’s action of rejecting the claim of 80G on CSR expenditure is justified. Hence, assessee’s appeal on this ground is dismissed.

59.

In the result, the appeal of the assessee is partly allowed.

1.

Order pronounced in accordance with Rule 34(4) of the Income Tax (Appellate Tribunal) Rules, 1963 as on 16 .12.2025

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