Held that the decision of the Delhi High Court in Principal CIT v. DCM Shriram Ltd. (2025) 344 CTR 817(Delhi) (HC) was not before the DRP, it is required to revisit its decision; order of the AO is set aside with the directions that the DRP may be requested by the AO/TPO, to reconsider the directions in the light of the amendment in the definition of ‘market value’ read with the decision of the Delhi High Court, examine the facts of the case and thereafter, modified directions, if required, may be issued to the AO for incorporation in the assessment order as per law. (AY. 2021-22)
Indian Metals & Ferro Alloys Ltd. v. AUID(2025) 237 TTJ 699 / 177 taxmann.com 586 (Cuttack)(Trib)
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of power by assessee’s eligible units to non-eligible units-Market value-Matter remanded.[S.80IA(8), 92BA]
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