https://www.taxtmi.com/caselaws?id=407375 For deduction under section 80IA(8), the market value of electricity transferred from a captive power plant to the manufacturing unit was benchmarked against the tariff the consuming unit would pay to the State Electricity Board in open-market conditions, not against a regulated long-term power purchase agreement rate. The Tribunal treated the Board tariff as a reliable external comparable, accepted the CUP method as the most appropriate method for this limited exercise, and held that the manufacturing unit could be the tested party. The transfer pricing adjustment was deleted and the deduction was to be recomputed on that basis. en-us Wed, 05 May 2021 00:00:00 +0530 Sat, 26 Oct 2024 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407375 For deduction under section 80IA(8), the market value of electricity transferred from a captive power plant to the manufacturing unit was benchmarked against the tariff the consuming unit would pay to the State Electricity Board in open-market conditions, not against a regulated long-term power purchase agreement rate. The Tribunal treated the Board tariff as a reliable external comparable, accepted the CUP method as the most appropriate method for this limited exercise, and held that the manufacturing unit could be the tested party. The transfer pricing adjustment was deleted and the deduction was to be recomputed on that basis. Case-Laws Income Tax Wed, 05 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407375