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INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
Rajesh Kumar, Accountant Member, Pradip Kumar Choubey, Judicial Member
DCIT – Appellant
Versus
Shyam Sel And Power Limited – Respondent
| Table of Content |
|---|
| 1. benchmarking transfer price of captive power at external market rates. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12) |
| 2. consistency in allocation methodology of common expenses across assessment years. (Para 13 , 14 , 15 , 16) |
| 3. mutatis mutandis application of established legal principles to subsequent appeals. (Para 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36) |
ORDER / आदेश
Per Rajesh Kumar, AM:
These are the appeals of Revenue against two different assessees' against the orders of the Commissioner of Income-tax (Appeals)-22, Kolkata (hereinafter referred to as the "Ld. CIT(A)"] for the AYs 2020-21 & 2021-22.
2. Since these appeals relate to the related companies and issues involved are mostly common, therefore these are being decided by this common order for the sake of convenience and brevity. First of all, we shall take up ITA No. 2663/KOL/2025 for A.Y. 2020-21 in case of Shyam Sel & Power Ltd.
ITA No. 2663/KOL/2025 (Revenue’s appeal)
3. The issue raised in Ground Nos.1 to 11 is against the order of ld. TPO/AO making downward adjustment of Rs.39,79,08,552/- in respect of transfer value of power by the capti
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