https://www.taxtmi.com/caselaws?id=237550 For deduction under s. 80-IA, the dominant issue was the determination of "market value" under s. 80-IA(8) for electricity transferred by a captive power plant to the assessee's own manufacturing unit. The HC held that the eligible business profits must be computed by adopting the open-market rate at which a consumer could purchase power, not the lower tariff applicable to sale of excess power to a supplier/board, because the latter is not the relevant market rate for internal consumption; the proviso permits reasonable computation only where the prescribed manner causes exceptional difficulty. Consequently, the AO's valuation based on supplier rates was illegal and the disallowance was set aside; the appeal was decided against the Revenue. en-us Fri, 02 Aug 2013 00:00:00 +0530 Sat, 10 Jan 2026 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=237550 For deduction under s. 80-IA, the dominant issue was the determination of "market value" under s. 80-IA(8) for electricity transferred by a captive power plant to the assessee's own manufacturing unit. The HC held that the eligible business profits must be computed by adopting the open-market rate at which a consumer could purchase power, not the lower tariff applicable to sale of excess power to a supplier/board, because the latter is not the relevant market rate for internal consumption; the proviso permits reasonable computation only where the prescribed manner causes exceptional difficulty. Consequently, the AO's valuation based on supplier rates was illegal and the disallowance was set aside; the appeal was decided against the Revenue. Case-Laws Income Tax Fri, 02 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=237550