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HC held that Comparable Uncontrolled Price (CUP) method was appropriate for determining Arm's Length Price (ALP) for power transfer between eligible and non-eligible units u/s 80IA. The court affirmed that Rs. 4.39 per kWh, being the rate at which assessee supplied excess power to UPPCL, constituted a valid internal uncontrolled transaction and was correctly accepted as ALP. Following precedent from Jindal Steel case, HC confirmed that State Electricity Board rates for industrial consumers represent market value u/s 80IA(8). The regulated nature of electricity market necessitates comparable transactions to be materially similar without price-affecting differences. Matter resolved in assessee's favor, validating their ALP computation methodology and transfer pricing adjustments.
HC held that Comparable Uncontrolled Price (CUP) method was appropriate for determining Arm's Length Price (ALP) for power transfer between eligible and non-eligible units u/s 80IA. The court affirmed that Rs. 4.39 per kWh, being the rate at which assessee supplied excess power to UPPCL, constituted a valid internal uncontrolled transaction and was correctly accepted as ALP. Following precedent from Jindal Steel case, HC confirmed that State Electricity Board rates for industrial consumers represent market value u/s 80IA(8). The regulated nature of electricity market necessitates comparable transactions to be materially similar without price-affecting differences. Matter resolved in assessee's favor, validating their ALP computation methodology and transfer pricing adjustments.
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