https://www.taxtmi.com/caselaws?id=465791 The dominant issue was determination of the arm's length/fair market value of electricity transferred by an eligible captive power plant to a non-eligible manufacturing unit for computing deduction under s. 80IA, read with ss. 80IA(8), 80A(6), 92 and 92F, treating the transfer as an SDT under s. 92BA. The ITAT (LB), by majority (JM and Third Member), held that the internal CUP being the tariff actually paid by the assessee to an independent distribution licensee at a regulated rate was a reliable benchmark reflecting market conditions; hence the rate charged (Rs. 6.62/unit) constituted the ALP. Consequently, the downward TP adjustment was deleted and deduction under s. 80IA was allowed without reduction on this ground. en-us Mon, 17 Nov 2025 00:00:00 +0530 Thu, 08 Jan 2026 18:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465791 The dominant issue was determination of the arm's length/fair market value of electricity transferred by an eligible captive power plant to a non-eligible manufacturing unit for computing deduction under s. 80IA, read with ss. 80IA(8), 80A(6), 92 and 92F, treating the transfer as an SDT under s. 92BA. The ITAT (LB), by majority (JM and Third Member), held that the internal CUP being the tariff actually paid by the assessee to an independent distribution licensee at a regulated rate was a reliable benchmark reflecting market conditions; hence the rate charged (Rs. 6.62/unit) constituted the ALP. Consequently, the downward TP adjustment was deleted and deduction under s. 80IA was allowed without reduction on this ground. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465791