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The ITAT directed the AO/TPO to base transfer pricing adjustments for electricity supplied from eligible to non-eligible units on the industry-standard transmission loss as determined by the Regulatory Authority, rather than the actual loss claimed by the assessee, which lacked supporting evidence. The transmission loss of 17.49% asserted by the assessee was rejected in the absence of proof, and the ALP was to be recalculated accordingly. Regarding steam transfer pricing, the Tribunal found the TPO's conversion method flawed and upheld the assessee's calculation, ordering the AO/TPO to recompute the cost of steam considering the assessee's submissions. Consequently, the ITAT partly allowed the appeal, mandating recalculation of transfer pricing adjustments for electricity and steam in line with prescribed regulatory norms and corrected methodologies.
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