https://www.taxtmi.com/caselaws?id=774896 The ITAT Delhi dismissed the assessee's challenge to TPO reference for ALP determination of domestic transactions. However, the Tribunal allowed appeals on electricity and steam transfer pricing adjustments. For electricity transfer from eligible to non-eligible units, the Tribunal accepted the assessee's pricing at MVVNL industrial consumer rates (Rs. 6.36 per unit) as arm's length, deleting the TPO's adjustment of Rs. 32,68,31,286. Regarding steam transfer, the Tribunal held steam is a commercial product with production costs, not a by-product at NIL value, following DCM Sriram Ltd. precedent, and deleted the Rs. 51,63,85,174 adjustment. The Tribunal remanded issues concerning 10% adhoc disallowance of professional charges and customs duty differences for fresh consideration by the AO. en-us Fri, 04 Jul 2025 00:00:00 +0530 Tue, 15 Jul 2025 10:43:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774896 The ITAT Delhi dismissed the assessee's challenge to TPO reference for ALP determination of domestic transactions. However, the Tribunal allowed appeals on electricity and steam transfer pricing adjustments. For electricity transfer from eligible to non-eligible units, the Tribunal accepted the assessee's pricing at MVVNL industrial consumer rates (Rs. 6.36 per unit) as arm's length, deleting the TPO's adjustment of Rs. 32,68,31,286. Regarding steam transfer, the Tribunal held steam is a commercial product with production costs, not a by-product at NIL value, following DCM Sriram Ltd. precedent, and deleted the Rs. 51,63,85,174 adjustment. The Tribunal remanded issues concerning 10% adhoc disallowance of professional charges and customs duty differences for fresh consideration by the AO. Case-Laws Income Tax Fri, 04 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774896