https://www.taxtmi.com/caselaws?id=764115 The ITAT Delhi ruled in favor of the assessee regarding transfer pricing adjustment for electricity supply between thermal unit and washeries division. The TPO had applied average rates from CSEB and IEX, arriving at Rs 2.868 per unit as ALP. However, citing SC precedent in Jindal Steel Power Ltd, the Tribunal held that market value should be determined by CSEB's rate to industrial consumers (Rs 4.05 per unit), not supplier rates. Since assessee's transfer price of Rs 4 per unit was within market rate of Rs 4.05, no adjustment was warranted. Issues regarding PF contribution and depreciation disallowance were remanded to AO for fresh adjudication. en-us Tue, 31 Dec 2024 00:00:00 +0530 Thu, 02 Jan 2025 11:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764115 The ITAT Delhi ruled in favor of the assessee regarding transfer pricing adjustment for electricity supply between thermal unit and washeries division. The TPO had applied average rates from CSEB and IEX, arriving at Rs 2.868 per unit as ALP. However, citing SC precedent in Jindal Steel Power Ltd, the Tribunal held that market value should be determined by CSEB's rate to industrial consumers (Rs 4.05 per unit), not supplier rates. Since assessee's transfer price of Rs 4 per unit was within market rate of Rs 4.05, no adjustment was warranted. Issues regarding PF contribution and depreciation disallowance were remanded to AO for fresh adjudication. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764115