https://www.taxtmi.com/caselaws?id=465427 Whether "market value" for s.80-IA(8) in respect of electricity captively consumed/surplus supplied should be benchmarked to the tariff paid by the State Electricity Board under statutory regulations/contract or to the rate charged to industrial/end consumers was the dominant issue. The Tribunal held that a price unilaterally determined by the Board under regulatory tariff and contractual terms cannot represent "market value" for s.80-IA(8); applying SC authority, as well as subsequent HC rulings post-amendment, the appropriate arm's length/market value is the rate at which the Board supplies power to end consumers in the open market. Consequently, the AO was directed to recompute the ALP and s.80-IA deduction adopting the assessee's market-based rate. en-us Wed, 13 Aug 2025 00:00:00 +0530 Fri, 19 Dec 2025 13:04:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465427 Whether "market value" for s.80-IA(8) in respect of electricity captively consumed/surplus supplied should be benchmarked to the tariff paid by the State Electricity Board under statutory regulations/contract or to the rate charged to industrial/end consumers was the dominant issue. The Tribunal held that a price unilaterally determined by the Board under regulatory tariff and contractual terms cannot represent "market value" for s.80-IA(8); applying SC authority, as well as subsequent HC rulings post-amendment, the appropriate arm's length/market value is the rate at which the Board supplies power to end consumers in the open market. Consequently, the AO was directed to recompute the ALP and s.80-IA deduction adopting the assessee's market-based rate. Case-Laws Income Tax Wed, 13 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465427