https://www.taxtmi.com/caselaws?id=774970 The ITAT Delhi ruled on transfer pricing adjustments involving electricity and steam transfers between eligible and non-eligible units. The assessee challenged adjustments made for electricity transfer from captive power division to other divisions and sale of power to RPG Industrial. The tribunal held that for electricity transfer pricing, approved/standard transmission losses prescribed by regulatory authorities should be used as benchmark rather than actual losses, which include extraordinary factors like theft and lightning not applicable in closed distribution environments. The 17.49% transmission loss claimed by assessee lacked supporting evidence, requiring verification against regulatory norms. For steam transfer, the tribunal found TPO's conversion methodology from HPS to LPS using kcal as common measurement unit incorrect, directing recalculation considering assessee's submissions. The AO/TPO was directed to rework pricing adjustments accordingly. Appeal was partly allowed for statistical purposes. en-us Fri, 27 Jun 2025 00:00:00 +0530 Wed, 16 Jul 2025 11:25:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774970 The ITAT Delhi ruled on transfer pricing adjustments involving electricity and steam transfers between eligible and non-eligible units. The assessee challenged adjustments made for electricity transfer from captive power division to other divisions and sale of power to RPG Industrial. The tribunal held that for electricity transfer pricing, approved/standard transmission losses prescribed by regulatory authorities should be used as benchmark rather than actual losses, which include extraordinary factors like theft and lightning not applicable in closed distribution environments. The 17.49% transmission loss claimed by assessee lacked supporting evidence, requiring verification against regulatory norms. For steam transfer, the tribunal found TPO's conversion methodology from HPS to LPS using kcal as common measurement unit incorrect, directing recalculation considering assessee's submissions. The AO/TPO was directed to rework pricing adjustments accordingly. Appeal was partly allowed for statistical purposes. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774970