https://www.taxtmi.com/caselaws?id=456252 For section 80IA(8), inter-unit electricity transfers must be valued at market value, and where the transfer is a specified domestic transaction, at arm's length price. The Tribunal treated the captive manufacturing unit as the relevant market context because the captive power plant existed to meet its own power needs and reduce purchase cost. It rejected comparison with regulated generator-to-distribution tariffs, which reflect a different market setting, and accepted the rate the manufacturing unit would pay the State Electricity Board as the more reliable comparable under similar conditions. The transfer pricing adjustment reducing the deduction was deleted. en-us Thu, 14 Dec 2023 00:00:00 +0530 Tue, 09 Jul 2024 19:58:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456252 For section 80IA(8), inter-unit electricity transfers must be valued at market value, and where the transfer is a specified domestic transaction, at arm's length price. The Tribunal treated the captive manufacturing unit as the relevant market context because the captive power plant existed to meet its own power needs and reduce purchase cost. It rejected comparison with regulated generator-to-distribution tariffs, which reflect a different market setting, and accepted the rate the manufacturing unit would pay the State Electricity Board as the more reliable comparable under similar conditions. The transfer pricing adjustment reducing the deduction was deleted. Case-Laws Income Tax Thu, 14 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456252