SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA
In the result, the appeal is partly allowed
ITA 527/ASR/2024[2020-21]Status: DisposedITAT Amritsar28 Feb 2025AY 2020-21
Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21
For Appellant: S/Shri Sudhir SehgalFor Respondent: Shri K. Mehboob Ali Khan, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 80
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the External Comparable Uncontrolled Price (CUP) method, which
could affect the determination of the arm's length price and,
consequently, the transfer pricing adjustments.
5.2 The assessee has established two captive electricity and steam
generation units (referred to as Co-generation Unit 1 and Co-
generation Unit 2) located in Muktsar, Punjab, for the generation of
electricity and steam
