Consumer-side electricity rates actually paid by cement units to...

Consumer-side electricity rates actually paid by cement units to independent distribution companies constituted valid internal comparable uncontrolled prices for captive power transfers under the specified domestic transaction regime. The arm's-length-price framework does not require exclusive use of generator-to-distribution-company rates; comparability under section 92C and Rule 10B remains transaction-specific. Although captive generators and distribution licensees have functional differences, those differences do not preclude comparison unless they materially affect it. Generator-side procurement rates were unsuitable because they reflected a different supply-chain stage, were not available to consuming units, and lacked comparability adjustments. The transfer-pricing adjustments were therefore deleted and that deletion sustained.