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The ITAT held that the transfer price of Rs. 4 per unit for supply of electricity from thermal unit to washeries division was at arm's length, being within the market rate of Rs. 4.05 per unit charged by CSEB to industrial consumers. No transfer pricing adjustment was warranted. The issues of employees' PF contribution and disallowance of depreciation were restored to the AO for de novo adjudication after considering facts pertaining to the assessee.
The ITAT held that the transfer price of Rs. 4 per unit for supply of electricity from thermal unit to washeries division was at arm's length, being within the market rate of Rs. 4.05 per unit charged by CSEB to industrial consumers. No transfer pricing adjustment was warranted. The issues of employees' PF contribution and disallowance of depreciation were restored to the AO for de novo adjudication after considering facts pertaining to the assessee.
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