https://www.taxtmi.com/caselaws?id=777088 ITAT, Cuttack set aside the AO's addition and directed the DRP to revisit its directions in light of the amended definition of "market value" and the HC decision on CUPs. The bench held that where an internal CUP exists the ALP is that internal rate; where no internal CUP exists, an external CUP based on distribution companies' retail rates should be used. The DRP/TPO/AO are to re-examine facts and, if required, issue modified directions for incorporation in the assessment. Appeal partly allowed for statistical purposes. en-us Tue, 19 Aug 2025 00:00:00 +0530 Sat, 23 Aug 2025 08:31:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777088 ITAT, Cuttack set aside the AO's addition and directed the DRP to revisit its directions in light of the amended definition of "market value" and the HC decision on CUPs. The bench held that where an internal CUP exists the ALP is that internal rate; where no internal CUP exists, an external CUP based on distribution companies' retail rates should be used. The DRP/TPO/AO are to re-examine facts and, if required, issue modified directions for incorporation in the assessment. Appeal partly allowed for statistical purposes. Case-Laws Income Tax Tue, 19 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777088