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    <title>2025 (1) TMI 1533 - ITAT JAIPUR</title>
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    <description>Where no deduction under section 80-IA was actually claimed because the assessee&#039;s income was fully absorbed by brought-forward losses, a transfer pricing adjustment for electricity transferred from captive power and wind power plants could not be sustained and was deleted. For section 80-IA valuation, the appropriate arm&#039;s length benchmark for electricity transferred between eligible and non-eligible units was the tariff charged by the State electricity distribution company to industrial consumers, not a different regulated procurement rate, so the assessee&#039;s adopted price was accepted. The modified return filed after amalgamation approval was also required to be considered for taxable income and carry-forward claims, with the rectification request directed to be dealt with in accordance with law.</description>
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      <description>Where no deduction under section 80-IA was actually claimed because the assessee&#039;s income was fully absorbed by brought-forward losses, a transfer pricing adjustment for electricity transferred from captive power and wind power plants could not be sustained and was deleted. For section 80-IA valuation, the appropriate arm&#039;s length benchmark for electricity transferred between eligible and non-eligible units was the tariff charged by the State electricity distribution company to industrial consumers, not a different regulated procurement rate, so the assessee&#039;s adopted price was accepted. The modified return filed after amalgamation approval was also required to be considered for taxable income and carry-forward claims, with the rectification request directed to be dealt with in accordance with law.</description>
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