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        Case ID :
        Income Tax

        TP Adjustment - IEX rates for the purpose of benchmarking the...

        Court Rules IEX Rates Unreliable for Transfer Pricing; Validates Assessee's Benchmarking u/s 92C (2.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TP Adjustment - IEX rates for the purpose of benchmarking the transaction of sale of power - if the prices are so divergent and the difference between the two external cup becomes irreconcilable, the external cup price which is more reliable should be used. Therefore, in our view, IEX rates for these reasons cannot be said to be an external cup available for invoking the provisions of first proviso to Section 92C (2) of the act. - No infirmity in the benchmarking analysis of the assessee wherein the assessee has considered rate of ₹ 6.30 per kilowatt against the rate of power purchase paid by the assessee to Jaipur Vidyiut Vitran Nigam Limited at the rate of ₹ 8.35 per kilowatt, using the external cup for comparability. - AT
                                Note: It is a system-generated summary and is for quick reference only.
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