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4 results for “transfer pricing”+ Section 391clear

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Key Topics

Section 260A4Section 80A3Section 92F3Section 92B3Section 803Section 93Transfer Pricing3Comparables/TP3Section 22

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

In the result, these appeals are dismissed and the substantial

ITAT/216/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

transfer price of power supplied by CPP was to be bench marked at annual average of landed cost at which power was being purchased by manufacturing units from State Electricity Board. The revenue carried the matter on appeal before this court and the appeal filed by the revenue was dismissed and the said decision is reported in (2025) 172 taxman.com

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

Section 422

In the result, these appeals are dismissed and the substantial

ITAT/217/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

transfer price of power supplied by CPP was to be bench marked at annual average of landed cost at which power was being purchased by manufacturing units from State Electricity Board. The revenue carried the matter on appeal before this court and the appeal filed by the revenue was dismissed and the said decision is reported in (2025) 172 taxman.com

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

In the result, these appeals are dismissed and the substantial

ITAT/215/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

transfer price of power supplied by CPP was to be bench marked at annual average of landed cost at which power was being purchased by manufacturing units from State Electricity Board. The revenue carried the matter on appeal before this court and the appeal filed by the revenue was dismissed and the said decision is reported in (2025) 172 taxman.com

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S DHUNSERI VENTURES LTD

Accordingly, the appeal fails and the same is dismissed

ITA/25/2024HC Calcutta20 Aug 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 20Th August, 2025. Appearance : Mr. Tilak Mitra, Adv. Mr. Prithu Dudhorea, Adv. …For Appellant.

Section 1Section 2Section 2(8)Section 260ASection 42Section 9

391 as well as the decision in Principal Commissioner of Income Tax, Central-I vs. Rungta Mines Ltd., [2025] 176 taxmann.com 410 [Cal]. The ratio of the said decision being that where assessee transferred power from its Captive Power 2 Plants [CPPs] to non-eligible units and benchmarked transaction using internal CUP method adopting average annual landed cost of electricity