https://www.taxtmi.com/caselaws?id=755349 For section 80IA(8), the Explanation treats market value in specified domestic transactions as arm's length price, so the correct CUP benchmark depends on comparable goods and comparable market conditions. Where electricity is transferred from a captive power plant to a related manufacturing unit for captive consumption, the relevant uncontrolled price may be the tariff payable by the industrial consumer to the State Electricity Board, because it reflects the price the unit would pay in the open market. The article states that this consumer-side SEB rate was upheld as the proper benchmark, and the transfer pricing adjustment was not sustained. en-us Fri, 15 Dec 2023 00:00:00 +0530 Wed, 10 Jul 2024 08:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755349 For section 80IA(8), the Explanation treats market value in specified domestic transactions as arm's length price, so the correct CUP benchmark depends on comparable goods and comparable market conditions. Where electricity is transferred from a captive power plant to a related manufacturing unit for captive consumption, the relevant uncontrolled price may be the tariff payable by the industrial consumer to the State Electricity Board, because it reflects the price the unit would pay in the open market. The article states that this consumer-side SEB rate was upheld as the proper benchmark, and the transfer pricing adjustment was not sustained. Case-Laws Income Tax Fri, 15 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755349