https://www.taxtmi.com/caselaws?id=777196 For section 80-IA valuation of electricity supplied from captive power plants, the proper benchmark is the State Electricity Board tariff charged to industrial consumers, because market value must reflect the consumer-side rate rather than a supplier-side sale rate. On that basis, the Tribunal's internal CUP approach was treated as correct and the Revenue's challenge failed. On corporate guarantee fee, the 0.5% benchmark was treated as a factual determination based on the material before the Tribunal, and the Revenue's own reliance on that rate meant no substantial question of law arose for appellate interference. en-us Wed, 20 Aug 2025 00:00:00 +0530 Tue, 26 Aug 2025 08:41:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777196 For section 80-IA valuation of electricity supplied from captive power plants, the proper benchmark is the State Electricity Board tariff charged to industrial consumers, because market value must reflect the consumer-side rate rather than a supplier-side sale rate. On that basis, the Tribunal's internal CUP approach was treated as correct and the Revenue's challenge failed. On corporate guarantee fee, the 0.5% benchmark was treated as a factual determination based on the material before the Tribunal, and the Revenue's own reliance on that rate meant no substantial question of law arose for appellate interference. Case-Laws Income Tax Wed, 20 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777196