https://www.taxtmi.com/caselaws?id=765121 ITAT Hyderabad held that section 92BA applies even when the assessee has not claimed deduction under section 80IA. The tribunal ruled that eligibility for section 80IA deduction does not depend on actually claiming it, as the assessee can exercise this option for any 10 consecutive years out of 15. For transfer pricing, the tribunal upheld using internal comparables (electricity supply to 14 consumers at average Rs. 2.97/unit) over state utility tariff (Rs. 7.85/unit) for benchmarking related party transactions, as the assessee operates as a power generator requiring comparison with similar entities rather than distribution companies. en-us Thu, 23 Jan 2025 00:00:00 +0530 Sat, 02 May 2026 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765121 ITAT Hyderabad held that section 92BA applies even when the assessee has not claimed deduction under section 80IA. The tribunal ruled that eligibility for section 80IA deduction does not depend on actually claiming it, as the assessee can exercise this option for any 10 consecutive years out of 15. For transfer pricing, the tribunal upheld using internal comparables (electricity supply to 14 consumers at average Rs. 2.97/unit) over state utility tariff (Rs. 7.85/unit) for benchmarking related party transactions, as the assessee operates as a power generator requiring comparison with similar entities rather than distribution companies. Case-Laws Income Tax Thu, 23 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765121