https://www.taxtmi.com/caselaws?id=754263 The ITAT Mumbai ruled on two transfer pricing issues. First, regarding inter-unit power transfer from an 80-IA eligible undertaking, the Tribunal held that Gujarat Electricity Board (GEB) rates were the correct benchmark for comparison under the Comparable Uncontrolled Price method, rejecting the TPO's adjustment. The Tribunal followed its own precedent for AY 2017-18, stating GEB's electricity supply rate to non-eligible units was appropriate for external comparison rather than Indian Energy Exchange rates. Second, the Tribunal admitted an additional ground regarding steam transfer valuation under section 80-IA, finding it raised a legal issue with bona fide reasons for late submission. The matter was remitted to the Assessing Officer for fresh consideration on whether market value should determine the deduction calculation. en-us Tue, 28 May 2024 00:00:00 +0530 Wed, 19 Jun 2024 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754263 The ITAT Mumbai ruled on two transfer pricing issues. First, regarding inter-unit power transfer from an 80-IA eligible undertaking, the Tribunal held that Gujarat Electricity Board (GEB) rates were the correct benchmark for comparison under the Comparable Uncontrolled Price method, rejecting the TPO's adjustment. The Tribunal followed its own precedent for AY 2017-18, stating GEB's electricity supply rate to non-eligible units was appropriate for external comparison rather than Indian Energy Exchange rates. Second, the Tribunal admitted an additional ground regarding steam transfer valuation under section 80-IA, finding it raised a legal issue with bona fide reasons for late submission. The matter was remitted to the Assessing Officer for fresh consideration on whether market value should determine the deduction calculation. Case-Laws Income Tax Tue, 28 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754263