https://www.taxtmi.com/caselaws?id=755349 For deduction under section 80IA(8), electricity transferred from captive power plants to non-eligible manufacturing units may be valued at the arm's length price using the comparable uncontrolled price method. The relevant comparable is the tariff payable by the captive manufacturing unit to the State Electricity Board, rather than the price at which generating companies sell power to distribution companies, because the transfer concerns captive consumption and the consumer-side tariff reflects the price payable in comparable market conditions. This approach recognises changes in the electricity market following the Electricity Act, 2003. Benchmarking based on the State Electricity Board consumer tariff was upheld, with no transfer-pricing adjustment 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 deduction under section 80IA(8), electricity transferred from captive power plants to non-eligible manufacturing units may be valued at the arm's length price using the comparable uncontrolled price method. The relevant comparable is the tariff payable by the captive manufacturing unit to the State Electricity Board, rather than the price at which generating companies sell power to distribution companies, because the transfer concerns captive consumption and the consumer-side tariff reflects the price payable in comparable market conditions. This approach recognises changes in the electricity market following the Electricity Act, 2003. Benchmarking based on the State Electricity Board consumer tariff was upheld, with no transfer-pricing adjustment sustained. Case-Laws Income Tax Fri, 15 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755349